OIG
Correctional Training Facility Cycle 6 Medical Inspection Report
Read the report at CDCR ↗
Amarik K. Singh, Inspector General Neil Robertson, Chief Deputy Inspector General
OFFICE of the
OIG
INSPECTOR GENERAL
Independent Prison Oversight September 2022
Cycle 6
Medical Inspection
Report
Correctional Training
Facility
Revised on 9-15-22; see next page for explanation.
Report revised and republished on 9-15-22: On page 2 the second paragraph was edited to clarify this institution
was delegated back to CDCR by the receiver.
Electronic copies of reports published by the Office of the Inspector General
are available free in portable document format (PDF) on our website.
We also offer an online subscription service.
For information on how to subscribe,
visit www.oig.ca.gov.
For questions concerning the contents of this report,
please contact Shaun Spillane, Public Information Officer,
at 916-255-1131.
Cycle 6, Correctional Training Facility | iii
Contents
Introduction 1
Summary 3
Overall Rating: Inadequate 3
Medical Inspection Results 7
Deficiencies Identified During Case Review 7
Case Review Results 7
Compliance Testing Results 7
Population-Based Metrics 8
HEDIS Results 9
Recommendations 11
Access to Care 14
Diagnostic Services 20
Emergency Services 24
Health Information Management 29
Health Care Environment 35
Transfers 42
Medication Management 49
Preventive Services 57
Nursing Performance 60
Provider Performance 66
Specialized Medical Housing 71
Specialty Services 76
Administrative Operations 82
Appendix A: Methodology 86
Case Reviews 87
Compliance Testing 90
Indicator Ratings and the Overall Medical Quality Rating 91
Appendix B: Case Review Data 92
Appendix C. Compliance Sampling Methodology 95
California Correctional Health Care Services’ Response 104
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Illustrations
Tables
1. CTF Summary Table 3
2. CTF Policy Compliance Scores 4
3. CTF Master Registry Data as of September 2021 5
4. CTF Health Care Staffing Resources as of August 2021 6
5. CTF Results Compared With State HEDIS Scores 10
6. Access to Care 17
7. Other Tests Related to Access to Care 18
8. Diagnostic Services 22
9. Health Information Management 32
10. Other Tests Related to Health Information Management 33
11. Health Care Environment 40
12. Transfers 46
13. Other Tests Related to Transfers 47
14. Medication Management 54
15. Other Tests Related to Medication Management 55
16. Preventive Services 58
17. Specialized Medical Housing 74
18. Specialty Services 79
19. Other Tests Related to Specialty Services 80
20. Administrative Operations 83
A–1. Case Review Definitions 87
B–1. Case Review Sample Sets 92
B–2. Case Review Chronic Care Diagnoses 93
B–3. Case Review Events by Program 94
B–4. Case Review Sample Summary 94
Figures
A-1. Inspection Indicator Review Distribution for CTF 86
A–2. Case Review Testing 89
A–3. Compliance Sampling Methodology 90
Photographs
1. B North Specialty Clinic Outdoor Waiting Area 35
2. North Clinic Indoor Waiting Area 36
3. Multiple Patients Serviced at the Same Time in the Triage Station and in Close Proximity 36
4. Examination Rooms That Lacked Visual Privacy When Conducting Patient Examinations 37
5. Expired Medical Supplies Dated March 2021 37
6. Expired Medical Supplies Dated September 11, 2021 37
7. Unlabeled and Disorganized Medical Supplies; Also Unsanitary Storage of Tongue Depressors 38
8. EMRB Compromised Oral Airway Sterile Packaging 38
Cover: Rod of Asclepius courtesy of Thomas Shafee
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
Cycle 6, Correctional Training Facility | 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the
Inspector General (the OIG) is responsible for periodically reviewing and
reporting on the delivery of the ongoing medical care provided to incarcerated
persons1 in the California Department of Corrections and Rehabilitation (the
department).2
In Cycle 6, the OIG continues to apply the same assessment methodologies used
in Cycle 5, including clinical case review and compliance testing. These methods
provide an accurate assessment of how the institution’s health care systems
function regarding patients with the highest medical risk who tend to access
services at the highest rate. This information helps to assess the performance of
the institution in providing sustainable, adequate care.3
We continue to review institutional care using 15 indicators, as in prior cycles.
Using each of these indicators, our compliance inspectors collect data in answer
to compliance- and performance-related questions as established in the medical
inspection tool (MIT).4 We determine a total compliance score for each applicable
indicator and consider the MIT scores in the overall conclusion of the
institution’s performance. In addition, our clinicians complete document reviews
of individual cases and also perform on-site inspections, which include
interviews with staff.
In reviewing the cases, our clinicians examine whether providers used sound
medical judgment in the course of caring for a patient. In the event we find
errors, we determine whether such errors were clinically significant or led to a
significantly increased risk of harm to the patient.5 At the same time, our
clinicians examine whether the institution’s medical system mitigated the error.
The OIG rates the indicators as proficient, adequate, or inadequate.
1 In this report, we use the terms patient and patients to refer to incarcerated persons.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of
care, and the OIG explicitly makes no determination regarding the constitutionality of care the
department provides to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected
Healthcare Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
4 The department regularly updates its policies. The OIG updates our policy-compliance testing to
reflect the department’s updates and changes.
5 If we learn of a patient needing immediate care, we notify the institution’s chief
executive officer.
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The OIG has adjusted Cycle 6 reporting in two ways. First, commencing with
this reporting period, we interpret compliance and case review results together,
providing a more holistic assessment of the care; and second, we consider
whether institutional medical processes lead to identifying and correcting
provider or system errors. The review assesses the institution’s medical care on
both system and provider levels.
As we did during Cycle 5, our office is continuing to inspect both those
institutions remaining under federal receivership and those delegated back to the
department. There is no difference in the standards used for assessing a
delegated institution versus an institution not yet delegated. At the time of the
Cycle 6 inspection Correctional Training Facility (CTF), the receiver had
delegated this institution back to the department.
We completed our sixth inspection of CTF, and this report presents our
assessment of the health care provided at this institution during the inspection
period February 2021 and July 2021.6 The data obtained for CTF, and the on-site
inspections occurred during the COVID-19 pandemic.7
Correctional Training Facility (CTF) is located five miles north of the city of
Soledad, in Monterey County. The institution’s primary mission is to provide
custody, care, treatment, and rehabilitation for Level I and II general population.
CTF runs multiple medical clinics where staff members handle nonurgent
requests for medical services. The institution also treats patients needing urgent
or emergent care in its triage and treatment area (TTA) and treats patients
requiring outpatient health services and assistance with the activities of daily
living in its outpatient housing unit (OHU). In addition, patients departing from
or arriving to the institution are screened in receiving and release (R&R) clinic.
CCHCS has designated CTF as a basic care institution; these institutions are
predominantly located in rural areas, away from tertiary care centers and
specialty care providers whose services are likely to be used frequently by high-
risk patients.
6 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The
case reviews include emergency noncardiopulmonary resuscitation (non-CPR) reviews between
February 2021 and August 2021, CPR reviews between December 2020 and April 2021, death reviews
between June 2020 and July 2021, diabetes reviews between March 2021 and August 2021, RN sick call
reviews between January 2021 and August 2021, and outpatient housing unit (OHU) reviews between
June 2020 and July 2021.
7 As of May 7 2022,, the department reports on its public tracker that 90% of its incarcerated
population at CTF is fully vaccinated while 80% of CTF staff are fully vaccinated:
http://www.cdcr.ca.gov/covid19/population-status-tracking/.
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Cycle 6, Correctional Training Facility | 3
Summary
We completed the Cycle 6 inspection of CTF in December 2021. OIG
inspectors monitored the institution’s medical care that occurred between
February 2021 and July 2021.
The OIG rated the overall quality of health care at CTF as inadequate. We
list the individual indicators and ratings applicable for this institution in
Table 1 below.
Table 1. CTF Summary Table
Cycle 6 Cycle 6 Cycle 6 Change
Health Care Indicators Case Review Compliance Overall Since
Rating Rating Rating Cycle 5
Access to Care Proficient Proficient Proficient
Diagnostic Services Adequate Inadequate Adequate
Emergency Services Inadequate N/A Inadequate
Health Information Management Adequate Adequate Adequate
Health Care Environment N/A Inadequate Inadequate
Transfers Adequate Adequate Adequate
Medication Management Adequate Inadequate Inadequate
Prenatal and Postpartum Care N/A N/A N/A N/A
Preventive Services N/A Inadequate Inadequate
Nursing Performance Inadequate N/A Inadequate
Provider Performance Inadequate N/A Inadequate
Reception Center N/A N/A N/A N/A
Specialized Medical Housing Adequate Proficient Adequate
Specialty Services Adequate Inadequate Adequate
Administrative Operations† N/A Proficient Proficient
* The symbols in this column correspond to changes that occurred in indicator ratings between the medical
inspections conducted during Cycle 5 and Cycle 6. The equals sign means there was no change in the rating. The
single arrow means the rating rose or fell one level, and the double arrow means the rating rose or fell two levels
(green, from inadequate to proficient; pink, from proficient to inadequate).
† Administrative Operations is a secondary indicator and is not considered when rating the institution’s overall medical
quality.
Source: The Office of the Inspector General medical inspection results.
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The OIG completed the Cycle 6 inspection for Correctional Training Facility in
December 2021. OIG inspectors monitored the institution’s medical care that
occurred between February 2021 and July 2021.
To test the institution’s policy compliance, our compliance inspectors, (a team of
registered nurses) monitored the institution’s compliance with its medical
policies by answering a standardized set of questions that measure specific
elements of health care delivery. Our compliance inspectors examined 381
patient records and 1,058 data points and used the data to answer 88 policy
questions. In addition, we observed CTF processes during an on-site inspection
in October 2021. Table 2 below lists CTF’s average scores from Cycles 4, 5, and 6.
Table 2. CTF Policy Compliance Scores
Scoring Ranges
100%–85.0% 84.9%–75.0% 74.9%–0
Medical Cycle 4 Cycle 5 Cycle 6
Inspection Policy Compliance Category Average Average Average
Tool (MIT) Score Score Score
1 Access to Care 83.9% 78.2% 89.3%
2 Diagnostic Services 86.7% 80.7% 72.5%
4 Health Information Management 58.4% 92.0% 82.8%
5 Health Care Environment 63.5% 69.1% 57.5%
6 Transfers 66.6% 92.5% 80.0%
7 Medication Management 80.5% 75.2% 67.1%
8 Prenatal and Postpartum Care N/A N/A N/A
9 Preventive Services 53.8% 81.3% 59.4%
12 Reception Center N/A N/A N/A
13 Specialized Medical Housing 94.0% 56.7% 87.5%
14 Specialty Services 77.5% 81.7% 73.7%
15 Administrative Operations 71.6%* 71.8% 90.8%
* In Cycle 4, there were two secondary (administrative) indicators, and this score reflects the average of
those two scores. In Cycle 5 and moving forward, the two indicators were merged into one, with only one
score as the result.
Source: The Office of the Inspector General medical inspection results.
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The OIG clinicians (a team of physicians and nurse consultants) reviewed 58
cases, which contained 850 patient-related events. After examining the medical
records, our clinicians conducted a follow-up on-site inspection in December
2021 to verify their initial findings. The OIG physicians rated the quality of care
for 22 comprehensive case reviews. Of these 22 cases, our physicians rated 18
adequate and four inadequate. Our physicians did not find any adverse
deficiencies during this inspection.
The OIG then considered the results from both case review and compliance
testing, and drew overall conclusions, which we report in the health care
indicators.8 Multiple OIG physicians and nurses performed quality control
reviews; their subsequent collective deliberations ensured consistency, accuracy,
and thoroughness. Our clinicians acknowledged institutional structures that
catch and resolve mistakes that may occur throughout the delivery of care. As
noted above, we listed the individual indicators and ratings applicable for this
institution in Table 1, the CTF Summary Table.
In September 2021, the Health Care Services Master Registry showed that CTF
had a total population of 4,511. A breakdown of the medical risk level of the CTF
population as determined by the department is set forth in Table 3 below.9
Table 3. CTF Master Registry Data as of September 2021
Medical Risk Level Number of Patients Percentage
High 1 175 3.9%
High 2 428 9.5%
Medium 1,676 37.2%
Low 2,232 49.5%
Total 4,511 100.0%
Source: Data for the population medical risk level were obtained
from the CCHCS Master Registry dated 9-24-21.
8 The indicators for Reception Center and Prenatal Care do not apply to CTF.
9 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
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Based on staffing data the OIG obtained from California Correctional Health
Care Services (CCHCS), as identified in Table 4 below, CTF had 3.0 vacant
executive leadership positions, 1.0 primary care provider vacancies, 0.2 nursing
supervisor vacancies, and 2.6 nursing staff vacancies.
Table 4. CTF Health Care Staffing Resources as of September 2021
Executive Primary Care Nursing Nursing
Positions Leadership* Providers Supervisors Staff† Total
Authorized Positions 6.0 11.0 12.7 77.7 107.4
Filled by Civil Service 3.0 10.0 12.5 107.6 133.1
Vacant 3.0 1.0 .2 2.6 6.8
Percentage Filled by Civil Service 50.0% 90.9% 98.4% 138.5% 123.9%
Filled by Telemedicine 0 2.0 0 0 2.0
Percentage Filled by Telemedicine 0% 18.2% 0% 0% 1.9%
Filled by Registry 0 1.5 0 26.5 28.0
Percentage Filled by Registry 0% 13.6% 0% 34.1% 26.0%
Total Filled Positions 3.0 13.5 12.5 134.1 163.1
Total Percentage Filled 50.0% 122.7% 98.4% 172.6% 151.8%
Appointments in Last 12 Months 0 0 4.0 22.0 26.0
Redirected Staff 0 0 0 0 7.0
Staff on Extended Leave‡ 0 0 0 2.0 2.0
Adjusted Total: Filled Positions 3.0 13.5 18.5 148.0 184.0
Adjusted Total: Percentage Filled 50.0% 112.5% 91.6% 103.3% 102.5%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Notes: The OIG does not independently validate staffing data received from the department. Positions are based
on fractional time-base equivalents.
Source: Cycle 6 medical inspection preinspection questionnaire received September 2021, from California
Correctional Health Care Services.
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Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies
can be minor or significant, depending on the severity of the deficiency. An
adverse event occurs when the deficiency caused harm to the patient. All major
health care organizations identify and track adverse events. We identify
deficiencies and adverse events to highlight concerns regarding the provision of
care and for the benefit of the institution’s quality improvement program to
provide an impetus for improvement.10
The OIG did not find any adverse deficiencies at CTF during the Cycle 6
inspection.
Case Review Results
OIG case reviewers assessed 10 of the 15 indicators applicable to CTF. Of these
10 indicators, OIG clinicians rated one proficient, six adequate, and three
inadequate. The OIG physicians also rated the overall adequacy of care for each
of the 22 detailed case reviews they conducted. Of these 22 cases, 18 were
adequate and four were inadequate. In the 850 events reviewed, there were 210
deficiencies, 84 of which the OIG clinicians considered to be of such magnitude
that, if left unaddressed, would likely contribute to patient harm.
Our clinicians found the following strengths at CTF:
• Staff ensured excellent access to providers and nurses during the
review period.
• Staff performed well in the completion of diagnostic tests.
Our clinicians found CTF could improve in the following areas:
• Similar to Cycle 5, CTF’s emergency services continued to be poor;
both provider and nursing care needed improvement. The
Emergency Medical Response Review Committee (EMRRC) often did
not recognize the lapses in emergency care that we identified.
• Providers performed poorly in emergency care and chronic care,
which are essential aspects of patient care.
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable to CTF. Of
these 10 indicators, our compliance inspectors rated three proficient, two
10 For a further discussion of an adverse event, see Table A-1.
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adequate, and five inadequate. We tested policy compliance in the Health Care
Environment, Preventive Services, and Administrative Operations as these
indicators do not have a case review component.
CTF demonstrated a high rate of policy compliance in the following areas:
• Providers excelled in providing timely appointments for chronic care
patients, patients returning from hospital admission, and patients
returning from specialty services. Moreover, patients were referred
within required time frames to their providers upon arrival at the
institution.
• Nursing staff reviewed health care services request forms and
performed face-to-face encounters timely.
• Providers timely completed history and physical examinations for
patients admitted to the OHU.
CTF demonstrated a low rate of policy compliance in the following areas:
• Clinical staff did not consistently follow universal hand hygiene
precautions before or after patient encounters.
• Medical clinics lacked properly calibrated medical equipment and
the medical supplies needed to provide standard medical care.
• Nursing staff did not regularly inspect emergency response bags or
the treatment cart.
• CTF did not perform well in ensuring that approved specialty
services were provided within required time frames.
• Providers often did not communicate results of diagnostic services to
patients. Most letters communicating these results were missing the
date of the diagnostic service, the date of the results, and whether the
results were within normal limits.
Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted above, the
OIG presents selected measures from the Healthcare Effectiveness Data and
Information Set (HEDIS) for comparison purposes. The HEDIS is a set of
standardized quantitative performance measures designed by the National
Committee for Quality Assurance to ensure that the public has the data it needs
to compare the performance of health care plans. Because the Veterans
Administration no longer publishes its individual HEDIS scores, we removed
them from our comparison for Cycle 6. Likewise, Kaiser (commercial plan) no
longer publishes HEDIS scores. However, through the California Department of
Health Care Services’ Medi-Cal Managed Care Technical Report, the OIG obtained
Kaiser Medi-Cal HEDIS scores for three of five diabetic measures to use in
conducting our analysis, and we present them here for comparison.
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HEDIS Results
We used population-based metrics in considering CTF’s performance to assess
the macroscopic view of the institution’s health care delivery. CTF’s results
compared favorably with those found in State health plans for diabetic care
measures. We list the applicable HEDIS measures in Table 5.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal,
Kaiser Northern California (Medi-Cal), and Kaiser Southern California
(Medi-Cal)—CTF performed better in all three diabetic measures that have
statewide comparative data: HbA1c screening, poor HbA1c control, and blood
pressure control, with a score of 100 percent for HbA1c screening.
Immunizations
Statewide comparative data were also not available for immunization measures;
however, we include this data for informational purposes. CTF had a 77 percent
influenza immunization rate for adults 18 to 64 years old and a 76 percent
influenza immunization rate for adults 65 years of age and older.11 The
pneumococcal vaccine immunization rate was 92 percent.12
Cancer Screening
Statewide comparative data were not available for colorectal cancer screening;
however, we include these data for informational purposes. CTF had an 86
percent colorectal cancer screening rate.
11 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable
result.
12 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines
(PCV13, PCV 15, and PCV 20), or 23 valent pneumococcal vaccine (PPSV23), depending on the
patient’s medical conditions. For the adult population, the influenza or pneumococcal vaccine may
have been administered at a different institution other than the one in which the patient was
currently housed during the inspection period.
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Table 5. CTF Results Compared With State HEDIS Scores
California California
CTF
Kaiser Kaiser
California NorCal SoCal
Cycle 6 Medi-Cal Medi-Cal Medi-Cal
HEDIS Measure Results* 2018† 2018† 2018†
HbA1c Screening 100% 90% 94% 96%
Poor HbA1c Control (> 9.0%) ‡, § 11% 34% 25% 18%
HbA1c Control (< 8.0%) ‡ 78% – – –
Blood Pressure Control (< 140/90) ‡ 91% 65% 78% 84%
Eye Examinations 58% – – –
Influenza – Adults (18–64) 77% – – –
Influenza – Adults (65+) 76% – – –
Pneumococcal – Adults (65+) 92% – – –
Colorectal Cancer Screening 86% – – –
Notes and Sources
* Unless otherwise stated, data were collected in October 2021 by reviewing medical records from a sample of
CTF’s population of applicable patients. These random statistical sample sizes were based on a 95 percent
confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication
titled Medi-Cal Managed Care External Quality Review Technical Report, dated July 1, 2019–June 30, 2020
(published April 2021). www.dhcs.ca.gov/documents/MCQMD/CA2019-20-EQR-Technical-Report-Vol3-F2.pdf
‡ For this indicator, the entire applicable CTF population was tested.
§ For this measure only, a lower score is better.
Source: Institution information provided by the California Department of Corrections and Rehabilitation. Health
care plan data were obtained from the CCHCS Master Registry.
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Recommendations
As a result of our assessment of CTF’s performance, we offer the following
recommendations to the department:
Diagnostic Services
• The department should consider developing and implementing an
electronic solution to ensure that culture results from the laboratory
portal automatically populate into the electronic health record
system (EHRS).
• Medical leadership should remind providers to send patient
notification letters for diagnostic services with the appropriate key
elements required by CCHCS policy.
Emergency Services
• Medical leadership should consider performing and documenting
clinical reviews for patients who transfer to a higher level of care.
• The Chief Nurse Executive (CNE) should ensure that supervisors
reviewing transfers for a higher level of care identify nursing care
clinical deficits.
• The department should consider whether patient vital signs taken in
the triage and treatment area (TTA) can automatically populate into
the EHRS.
Health Information Management
• Medical leadership should consider routinely assessing each
provider’s message center to ensure providers are timely reviewing
and endorsing diagnostic and specialty reports.
Health Care Environment
• To ensure that staff are following equipment and medical supply
management protocols, nursing leadership should consider
performing random spot checks.
• Medical leadership should remind staff to follow universal hand
hygiene precautions. Implementing random spot checks could
improve compliance.
• Nursing leadership should direct nurse supervisors at each clinic to
review the monthly emergency medical response bag (EMRB) and
treatment cart logs to ensure they are regularly inventoried and
sealed.
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Transfers
• Nursing leadership should consider educating receiving and release
(R&R) nurses in the proper completion of initial health screening
questions.
Medication Management
• Medical and nursing leadership should ensure that chronic care,
hospital discharge, and en route patients receive their medications
timely and without interruption.
• Nursing leadership and the public health nurse should instruct
nursing staff to properly document the monitoring of patients taking
tuberculosis (TB) medications.
Preventive Services
• Nursing leadership and the public health nurse should instruct
nursing staff to properly document the monitoring of patients taking
tuberculosis (TB) medications.
• Nursing leadership should consider developing and implementing
measures to ensure that nursing staff timely screen patients for TB.
• Medical leadership should determine the root cause of challenges
that prevent the timely provision of chronic care vaccinations.
Nursing Performance
• The department should consider strategies to improve recruitment
and retention of nursing leadership and staff.
• Nursing executive leadership should ensure that nursing supervisors,
who conduct clinical care reviews, identify opportunities for
improvement.
Provider Performance
• To improve provider decision-making, medical leadership should
consider including a review of emergency care when completing
annual provider reviews.
• Medical leadership should remind providers to assess pertinent
physical findings for patient medical issues and document patient
encounters appropriately.
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Specialized Medical Housing
• Medical leadership should consider reminding OHU providers to
perform appropriate physical exams and document findings
accurately.13
Specialty Services
• Medical leadership should ensure that providers review and endorse
specialty reports timely.
• Medical leadership should ensure that the institution receives
specialty reports timely.
• Medical leadership should ensure that patients receive routine
specialty follow-up appointments timely.
• Medical leadership should ensure that patients who recently
transferred into the institution receive their previously scheduled
specialty appointments within the required time frames.
Administrative Operations
• Medical leadership should ensure that the institution’s Emergency
Medical Response Review Committee (EMRRC) review cases timely
and include all required documents.
13 OHU is the outpatient housing unit.
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Access to Care
Overall
Rating
In this indicator, OIG inspectors evaluated the institution’s performance in
providing patients with timely clinical appointments. Our inspectors reviewed Proficient
the scheduling and appointment timeliness for newly arrived patients, sick calls,
Case Review
and nurse follow-up appointments. We examined referrals to primary care
Rating
providers, provider follow-ups, and specialists. Furthermore, we evaluated the
follow-up appointments for patients who received specialty care or returned from Proficient
an off-site hospitalization.
Compliance
Score
Results Overview Proficient
(89.3%)
CTF provided excellent access to care. This was remarkable in light of the
impacts from COVID-19, which presented a unique challenge. We considered
specific concerns affecting CTF during the review period such as reducing
unnecessary appointments to minimize spread of COVID-19. However, it is
important not to reschedule or cancel appointments when patients need to be
seen clinically. The OIG case reviewers evaluated each case with the
understanding that these circumstances may have affected patient care.
CTF ensured that patients were seen by providers when nurses and providers
when medically necessary. Nurses reviewed sick calls and performed face-to-face
appointments timely. CTF also ensured that patients saw specialists as needed.
Providers in specialized medical housing also saw their patients appropriately.
Overall, the OIG rated this indicator proficient.
Case Review and Compliance Testing Results
We reviewed 372 provider, nursing, specialty, and hospital events that required
the institution to generate appointments. We identified nine deficiencies relating
to this indicator, seven of which were significant.14
Access to Clinic Providers
Access to clinic providers is an integral part of patient care in health care
delivery. In case review, CTF performed well with provider referrals and provider
follow-up requests. We reviewed 77 outpatient provider encounters and
identified four deficiencies.15
Compliance testing showed provider chronic care follow-up appointments,
nurse-to-provider sick call referrals, and provider follow-up appointments
occurred timely (MIT 1.001, 83.3%, MIT 1.005, 83.3%, MIT 1.006, 100%).Case
review clinicians also found CTF ensured that patients had good access to
14 Deficiencies occurred in cases 17, 24, 26, 30, 37, 38, 39, and 58. Significant deficiencies occurred in
cases 17, 24, 26, 37, 38, 39, and 58.
15 Deficiencies occurred in cases 17, 24, 26, and 39.
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providers. In the following cases, we identified several opportunities for
improvement:
• In case 17, the sick call nurse initiated a provider appointment for
flank pain, but this appointment did not occur. During the on-site
inspection, the provider explained that nurses generate a provider
appointment to have a nurse discussion with the provider and then
complete the appointment after their discussion. However, the
patient had flank pain with trace blood in his urine and should have
been seen by the provider.
• In case 39, the clinic nurse planned for the patient to have a follow-
up appointment with the provider within 14 days, but did not place
the order. By happenstance, the patient had a chronic care
appointment 19 days later.
Access to Specialized Medical Housing Providers
CTF performed very well with access to care in the outpatient housing unit
(OHU). Providers performed history and physical examinations promptly.
Compliance testing showed an excellent score (MIT 13.002, 100%) and case
reviewers found no deficiencies with access in the OHU.
Access to Clinic Nurses
CTF performed well with access to nursing sick calls and provider-to-nurse
referrals. Compliance testing showed that nurses reviewed patient sick-call
requests the same day they were received (MIT 1.003, 100%) and performed face-
to-face visits within one business day after the sick call was reviewed (MIT 1.004,
96.9%). Case review clinicians also found good performance in this area and only
found two instances in which sick call patients should have been seen sooner.
Access to Specialty Services
CTF’s performance was mixed in access to specialty appointments. Compliance
testing showed good high-priority (MIT 14.001, 80.0%), medium-priority (MIT
14.004, 93.3%) and routine-priority (MIT 14.007, 80.0%) access to specialty
services. Compliance testing showed timely high-priority (MIT 14.003, 90.0%) and
medium-priority (MIT 14.006, 100%) specialist follow-up appointments, but a lack
of timely routine-priority appointments (MIT 14.009, 50.0%). Case reviewers
found good access for specialty services at the institution. However, the following
was an example for improvement:
• In case 58, the pulmonologist recommended imaging studies and
specialty follow-up for the patient to rule out malignancy. This did
not occur until 11 months later.
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Follow-up After Specialty Service
CTF provided great access to providers after patients had specialty
appointments. Compliance testing showed very good score of 85.7 percent (MIT
1.008) and case review found patients were seen when medically necessary.
Patients were usually in COVID-19 quarantine after an off-site specialty
appointment. The OIG clinicians reviewed 68 specialty events and did not assign
deficiencies when CTF providers appropriately performed chart review to order
the necessary appointments, medications, and diagnostics.
Follow-up After Hospitalization
CTF provided excellent access to patients after they returned from the hospital.
Compliance testing showed providers followed up with patients after
hospitalization 100 percent of the time (MIT 1.007). Case review clinicians
reviewed 31 hospitalizations and found no deficiencies with delays or missed
appointments after hospitalization.
Follow-up After Urgent or Emergent Care (TTA)
CTF performed well for patients with provider follow-up appointments after
urgent care in the triage and treatment area (TTA). We reviewed 11 TTA events
in which patients needed and received provider follow-up, and found no
deficiencies.
Follow-up After Transferring Into the Institution
CTF performed well in providing initial provider appointments for newly arrived
patients within required time frames (MIT 1.002, 88.0%). Our case review
clinicians reviewed five transfer-in events and found only one minor delay with a
late provider appointment.
Clinician On-Site Inspection
We spoke with scheduling supervisors, utilization management, leadership,
providers, and nurses during the inspection process. They stated that the
COVID-19 pandemic impacted their access initially, but that they worked
diligently to ensure care for their patients. We attended morning huddles via
teleconferencing software and heard primary care teams discuss patients they
had on the schedule and any other patients that needed to be seen. At the time of
our on-site inspection, CTF reported no patient appointment backlogs. We
learned that in September 2020, CTF’s South facility was closed due to a decrease
in population numbers.
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Compliance Testing Results
TTaabbllee 66.. AAcccceessss ttoo CCaarree
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most
recent chronic care visit within the health care guideline’s maximum
20 4 1 83.3%
allowable interval or within the ordered time frame, whichever is
chgs per Ron, new Excel sheet shorter? (1.001) *
sent 3-14, 2 figs for 1.001 and a For endorsed patients received from another CDCR institution:
Based on the patient’s clinical risk level during the initial health
chg in percentage = 89.3 22 3 0 88.0%
screening, was the patient seen by the clinician within the required
time frame? (1.002) *
Clinical appointments: Did a registered nurse review the patient’s
32 0 0 100%
request for service the same day it was received? (1.003) *
Clinical appointments: Did the registered nurse complete a face-to-
face visit within one business day after the CDCR Form 7362 was 31 1 0 96.9%
reviewed? (1.004) *
Clinical appointments: If the registered nurse determined a referral
to a primary care provider was necessary, was the patient seen within
5 1 26 83.3%
the maximum allowable time or the ordered time frame, whichever is
the shorter? (1.005) *
Sick call follow-up appointments: If the primary care provider ordered
a follow-up sick call appointment, did it take place within the time 1 0 31 100%
frame specified? (1.006) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment within the required time 20 0 0 100%
frame? (1.007) *
Specialty service follow-up appointments: Did the clinician follow-up
visits occur within required time frames? (1.008)
*,† 30 5 10 85.7%
Clinical appointments: Do patients have a standardized process to
4 2 0 66.7%
obtain and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 89.3%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician
follow-up visits following specialty services. As a result, we tested MIT 1.008 only for high-priority
specialty services or when staff ordered follow-ups. The OIG continued to test the clinical appropriateness
of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Table 7. Other Tests Related to Access to Care
Table 7. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the N/A N/A N/A N/A
required time frame? (12.003) *
For patients received from a county jail: Did the patient receive a
history and physical by a primary care provider within seven calendar N/A N/A N/A N/A
days? (12.004) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time 4 0 0 100%
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior to
4/2019): Did the primary care provider complete the Subjective, Objective,
0 0 4 N/A
Assessment, and Plan notes on the patient at the minimum intervals
required for the type of facility where the patient was treated? (13.003)
*,†
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 12 3 0 80.0%
Request for Service? (14.001) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 9 1 5 90.0%
(14.003) *
Did the patient receive the medium-priority specialty service within
15-45 calendar days of the primary care provider order or the Physician 14 1 0 93.3%
Request for Service? (14.004) *
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary care 11 0 4 100%
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 12 3 0 80.0%
Request for Service? (14.007) *
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 3 3 9 50.0%
(14.009) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still had state-
mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of provider
follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Diagnostic Services
Overall
Rating
In this indicator, OIG inspectors evaluated the institution’s performance in
Adequate
timely completing radiology, laboratory, and pathology tests. Our inspectors
determined whether the institution properly retrieved the resultant reports and
Case Review
whether providers reviewed the results correctly. In addition, in Cycle 6, we
Rating
examined the institution’s performance in timely completing and reviewing
Adequate
immediate (STAT) laboratory tests.
Compliance
Score
Results Overview
Inadequate
(72.5%)
CTF performed well in completing and retrieving diagnostic tests, with the
exception of culture results. The institution completed tests timely, and providers
reviewed and endorsed laboratory and radiology reports within required time
frames. The institution had difficulty both with incomplete patient result
notification letters and not sending patient notification letters. Compliance
testing also revealed that the institution did not send patient notification letters
for pathology reports. Considering the findings from case review and compliance
testing, we rated this indicator adequate.
Case Review and Compliance Testing Results
We reviewed 235 diagnostic event and found 15 deficiencies, four of which were
significant. All deficiencies we found were related to health information
management. There were no deficiencies pertaining to the completion of
diagnostic tests.16
Test Completion
CTF performed very well with completion of diagnostic tests. Compliance testing
found that X-rays were completed timely 100 percent of the time (MIT 2.001) and
laboratory tests were completed timely 90.0 percent of the time (MIT 2.004).
There were no STAT laboratory tests available for compliance testing or case
review. Case review did not identify any deficiencies related to test completion of
diagnostic studies.
Health Information Management
Providers reviewed radiology (MIT 2.002, 90.0%) and laboratory (MIT 2.005, 100%)
reports timely. The institution retrieved pathology reports (MIT 2.010, 80.0%) and
reviewed (MIT 2.011, 75.0%) them timely, but did not communicate the results to
patients timely (MIT 2.012, 37.5%).
16 Deficiencies occurred in cases 1, 10, 11, 12, 14, 16, 18, 20, 23, 24, 27, and 58. Significant deficiencies
occurred in cases 1, 14, 20, and 24.
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Our case review clinicians identified a few issues with CTF’s information
management of diagnostic reports. An important concern was that laboratory
culture results do not auto populate from the laboratory into the EHRS. The
following are examples:
• In case 1, the patient had a urinary bacterial infection; however, the
urine culture result was not available in the EHRS.
• In case 24, the patient had a negative fungal smear, but the final
culture showed a specific fungus. However, this final culture result
was not in the EHRS.
Another prevalent issue that case reviews identified was related to patient
notifications. In five examples, providers did not send a patient notification letter
to inform the patient of their results. In five other occurrences, the patient
notification letter was missing at least one element required per policy.17
Clinician On-Site Inspection
We spoke with the laboratory supervisor, who reported no issues with collecting
laboratory samples or performing on-site radiology studies. The supervisor
explained that EHRS automatically sends notifications to the ordering provider
to review and endorse laboratory results.
17 Lack of patient test notification letters occurred in cases 14, 20, 23, and twice in 27. Notification
letters were missing required elements in cases 10, 12, 16, and 24.
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Compliance Testing Results
TTaabbllee 88.. DDiiaaggnnoossttiicc SSeerrvviicceess
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001) *
Radiology: Did the ordering health care provider review and endorse
9 1 0 90.0%
the radiology report within specified time frames? (2.002) *
Radiology: Did the ordering health care provider communicate the
results of the radiology study to the patient within specified time 6 4 0 60.0%
frames? (2.003)
Laboratory: Was the laboratory service provided within the time
9 1 0 90.0%
frame specified in the health care provider’s order? (2.004) *
Laboratory: Did the health care provider review and endorse the
10 0 0 100%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the health care provider communicate the results
of the laboratory test to the patient within specified time frames? 2 8 0 20.0%
(2.006)
Laboratory: Did the institution collect the STAT laboratory test and
N/A N/A N/A N/A
receive the results within the required time frames? (2.007) *
Laboratory: Did the provider acknowledge the STAT results, OR did
nursing staff notify the provider within the required time frames? N/A N/A N/A N/A
(2.008) *
Laboratory: Did the health care provider endorse the STAT laboratory
N/A N/A N/A N/A
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report
8 2 0 80.0%
within the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
6 2 2 75.0%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results
of the pathology study to the patient within specified time frames? 3 5 2 37.5%
(2.012)
Overall percentage (MIT 2): 72.5%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• The department should consider developing and implementing an
electronic solution to ensure that culture results from the laboratory
portal automatically populate into the electronic health record
system (EHRS).
• Medical leadership should remind providers to send patient
notification letters for diagnostic services with the appropriate key
elements required by CCHCS policy.
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Emergency Services
Overall
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Rating
Our clinicians reviewed emergency medical services by examining the timeliness Inadequate
and appropriateness of clinical decisions made during medical emergencies. Our
evaluation included examining the emergency medical response, Case Review
cardiopulmonary resuscitation (CPR) quality, triage and treatment area (TTA) Rating
care, provider performance, and nursing performance. Our clinicians also Inadequate
evaluated the Emergency Medical Response Review Committee’s (EMRRC)
Compliance
performance in identifying problems with its emergency services. The OIG
Score
assessed the institution’s emergency services mainly through case review only.
(N/A)
Results Overview
Similar to Cycle 5, CTF continued to deliver poor emergency care. Providers and
nurses made poor clinical decisions and did not always recognize potentially
urgent symptoms in patients. In addition, TTA nurses did not always provide
complete physical assessments or sufficiently monitor patients. Furthermore, the
institution’s emergency medical response review process did not identify all
clinical opportunities for improvement. The OIG rated this indicator inadequate.
Case Review Results
We reviewed 31 urgent or emergent events and found 56 emergency care
deficiencies, 19 of which were significant.18
Emergency Medical Response
CTF staff generally responded appropriately to emergency events; first medical
responders evaluated the patient and situation, requested clinical health care
staff timely, and notified emergency medical services without delay. Our
clinicians reviewed 14 events that involved a first medical responder and
identified both documentation and assessment deficiencies.19 These
documentation deficiencies did not affect the overall patient care.
In one of the five CPR events we reviewed, there was a delay in initiating CPR.20
Although custody staff determined the patient was not breathing and requested
medical staff, first responders did not start CPR for five minutes.
18 Deficiencies occurred in cases 1, 2, 3, 4, 5, 6, 7, 8, 9, 11, 17, 19–22, and 24. Cases 1, 3, 4, 9, 11, 17, 19,
21, and 24 had significant deficiencies.
19 Documentation deficiencies occurred in cases 3, 6, 8, and 21. Assessment deficiencies occurred in
cases 1, 3, and 19.
20 A delay in CPR occurred in case 3.
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Provider Performance
We reviewed 24 emergency events in which providers either evaluated the patient
directly or were consulted by telephone, and identified seven deficiencies.21 The
providers did performed poorly with urgent and emergent care. Providers needed
to have a higher level of consideration of life-threatening conditions in
emergency situations. There were a few instances in which providers did not
document their decision-making process, and it was unclear whether they
considered the potential severe consequence of the patient’s symptom. A
compounding issue was that these deficiencies were not identified and discussed
during EMRRC meetings. It is difficult to improve performance if opportunities
for improvement are not identified. The following are some examples:
• In case 17, the patient, who had cardiac risk factors and chest pain,
was evaluated in the TTA. The on call provider only recommended a
follow-up with the RN instead of a provider. The patient required
either an in-person provider evaluation during the TTA event or a
close in-person provider follow-up.
• In case 19, the patient who had pain in his left side was in the TTA
with pneumonia. The provider on call was notified that the patient’s
oxygen levels had dropped significantly and the patient’s heart rate
increased with exertion. The provider did not send the patient to the
hospital in an ambulance and decided to use a state car instead,
which placed the patient at further medical risk.
• In case 21, the patient had chest pain, shortness of breath, and a
recent cardiac stress test that indicated reduced blood flow to parts
of the heart. The provider on call did not send the patient out to the
hospital or ensure an urgent cardiology follow-up. The patient had a
heart attack about one month later.
Nursing Performance
The OIG clinicians found that TTA nurses did not always make safe, appropriate
triage decisions, and frequently made incomplete assessments and interventions
for their patients. Compared to Cycle 5, we identified more significant
deficiencies.22 Following are some examples:
• In case 1, a psychiatric technician contacted the TTA RN regarding a
patient with severe abdominal pain, high blood pressure, and a fast
heart rate. The RN did not arrange a medical transport to the TTA,
and instead, inappropriately instructed the patient to walk to the
21 Provider deficiencies occurred in cases 1, 2, 17, 19, 21, and 24.
22 Significant deficiencies occurred in cases 4, 9, 11, and 21. Significant deficiencies occurred on three
occasions in case 1.
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TTA. In addition, the RN did not perform a full reassessment of the
patient after the initial evaluation.
• In case 9, the high-risk, 62-year-old patient had a decrease in oxygen
levels. A nurse who was conducting COVID-19 rounds, contacted a
TTA RN to evaluate the patient. However, the TTA RN did not assess
the patient until one hour and fifty minutes later, at which time the
patient’s oxygen levels had further declined, and the patient required
administration of supplemental oxygen and a transfer to a higher
level of care.
• In case 11, the patient had low blood oxygen levels. The TTA RN did
not respond to a medical alarm for the patient, and instead,
instructed the LVN to escort the patient to the TTA. Subsequently,
there was a delay in administering oxygen to the patient. Once the
patient arrived to the TTA, the RN found that the patient also had an
unsteady gait, a swollen abdomen, and lower extremity weakness and
numbness. However, the TTA RN did not consult a provider about
these abnormal findings for one hour and 35 minutes and also did
not reevaluate the patient’s abnormal findings or monitor the
patient’s blood pressure, pulse, and respiratory rates for four hours.
• In case 21, a TTA RN evaluated the patient, who complained of chest
pain. The nurse identified both subjective and objective findings
consistent for a myocardial infarction (heart attack). However, the
nurse did not follow the CCHCS nursing chest pain protocol and
administer aspirin to the patient.
Nursing Documentation
Nursing documentation in CTF’s TTA was frequently incomplete. We found that
nurses did not always document their assessment findings and interventions
thoroughly. At times, TTA nurses documented timeline information inaccurately
or failed to document this information at all. The following are some examples:
• In case 1, the nurse noted the patient had an abdominal wound, but
did not document the size of the wound or the presence of the
wound’s dressing.
• In case 5, the nurse did not document the TTA arrival and departure
times of emergency medical personnel. Similar findings were also
identified in cases 1, 2, 3, and 20.
• In case 8, a TTA nurse documented that the patient’s vital signs were
monitored every five minutes, but did not document the results.
Emergency Medical Response Review Committee (EMRRC)
Our clinicians reviewed 10 cases in which patients were transferred to a higher
level of care and identified several opportunities for improvements. We found
that nursing supervisors frequently reviewed the transfer events, but there was
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no evidence of a physician clinical review. However, the OIG clinicians found
deficiencies not identified in the reviews of supervisors or by the EMRRC. In
addition, the EMRRC did not review the cases and incident packages timely (MIT
15.003, zero).
Clinician On-Site Inspection
CTF’s TTA was centrally located and had three beds. It was staffed with two RNs
for each shift. According to nurses, a provider was only intermittently assigned to
the TTA. However, even when a provider was assigned to the TTA, the provider
was sometimes redirected to a clinic. When a provider was not assigned to the
TTA, nurses consulted the patient’s primary care provider via phone during
business hours, or a provider on call if it was after business hours. During the
second and third shifts, the LVNs served as the first medical responders. TTA
RNs responded to all medical alarms on the first shifts.
In addition to the traditional TTA duties, we learned that at CTF the TTA nurses
also assisted when COVID-19 quarantined and isolated patients required care.
The nurses explained that during the institution’s COVID-19 outbreak, they were
very busy, and the volume of patients was challenging to manage at times.
According to the nurses, this made thorough documentation difficult. They
indicated it would be helpful if patient vital signs taken in the TTA would auto
populate into EHRS so they would not need to spend time manually entering this
data.
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Recommendations
• Medical leadership should consider performing and documenting
clinical reviews for patients who transfer to a higher level of care.
• The Chief Nurse Executive (CNE) should ensure that supervisors
reviewing transfers for a higher level of care identify nursing care
clinical deficits.
• The department should consider whether patient vital signs taken in
the triage and treatment area (TTA) can automatically populate into
the EHRS.
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Health Information Management
Overall
Rating
In this indicator, OIG inspectors evaluated the flow of health information, a
Adequate
crucial link in high-quality medical care delivery. Our inspectors examined
whether the institution retrieved and scanned critical health information
Case Review
(progress notes, diagnostic reports, specialist reports, and hospital discharge
Rating
reports) into the medical record in a timely manner. Our inspectors also tested
Adequate
whether clinicians adequately reviewed and endorsed those reports. In addition,
our inspectors checked whether staff labeled and organized documents in the Compliance
medical record correctly. Score
Adequate
(82.8%)
Results Overview
Overall, CTF performed satisfactorily in health information management. The
institution had excellent performance in hospital and emergency health
information. Performance in diagnostics was good; however, patient notification
of pathology results was lacking. Both compliance testing and case review
identified specialty information management as an area that needed
improvement. We reviewed the various levels of performance and rated this
indicator adequate.
Case Review and Compliance Results
OIG clinicians reviewed 851 events and found 41 deficiencies related to health
information management, 18 of which were significant.23
Hospital Discharge Reports
CTF performed very well with management of hospital discharge reports. Our
clinicians reviewed 31 off-site emergency department and hospital visits, and
found no retrieval delays; however, we found two late endorsements and one
missing provider endorsement. Compliance testing showed a perfect score in the
retrieval and scanning reports into the EHRS (MIT 4.003, 100%), and in the
reviewing hospital discharge records (MIT 4.005, 100%).
Specialty Reports
CTF did not perform well in the management of specialty reports. While the
institution performed acceptably in scanning specialty reports timely (MIT 4.002,
76.7%), CTF performed poorly with retrieving of high-priority (MIT 14.002,
66.7%), medium-priority (MIT 14.005, 53.3%), and routine-priority specialty
reports (MIT 14.008, 61.5%). Our case review clinicians found a few delayed
23 Deficiencies occurred in cases 1, 2, 3, 5, 7–14, 16, 18–21, 23, 24, 26, 27, and 58. Significant
deficiencies occurred in cases 1, 8, 13, 14, 19–21, 23, 24, 26, 27, and 58.
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retrievals and a pattern of delayed provider reviews and endorsements.24 OIG
clinicians reviewed 46 specialty service encounters and found two delayed
retrievals and thirteen delayed provider reviews and endorsements.
• In case 8, the institution did not ensure that the provider endorsed
the gastroenterology consultation within policy time frames; the
report was endorsed 10 days after it was available.
• In case 27, the institution retrieved the neurosurgery report 40 days
after the consultation.
Diagnostic Reports
CTF had a mixed performance in diagnostic reports. Compliance testing showed
providers reviewed and endorsed the pathology reports 75.0 percent of the time
(MIT 2.011); however, communicating the pathology results to the patient
revealed room for improvement (MIT 2.012, 37.5%). Our clinicians reviewed 240
diagnostic events and identified 15 deficiencies.25 Most deficiencies resulted from
providers sending patient notification letters late or not at all. There were no
applicable STAT laboratory tests to test or review during this inspection. Please
refer to the Diagnostic Services indicator for a detailed discussion about
diagnostics health information management.
Urgent and Emergent Records
OIG clinicians reviewed 45 emergency care events and found that the nurses
recorded these events well. The providers also recorded their emergency care
sufficiently, including the off-site telephone encounters. However, our clinicians
found that the AED discharge summary was not scanned into the EHRS in three
different cases.26 The Emergency Services indicator provides additional
information regarding emergency care documentation.
Scanning Performance
CTF had a mixed performance in the scanning process. Compliance testing
found poor scanning performance (MIT 4.004, 37.5%); however, our clinicians
identified only a few scanning errors.27 The following is an example:
• In case 26, the report of the positron emission tomography (PET) and
computed tomography (CT) scans was not scanned into the patient’s
24 Retrieval deficiencies occurred in cases 26 and 27. Review and endorsement deficiencies occurred in
cases 8, 9, 13, 20, 21, 23, and 58.
25 Diagnostic health information management deficiencies occurred in cases 1, 10, 11, 12, 14, 16, 18,
20, 23, 24, 27, and 58. Significant deficiencies occurred in cases 1, 14, 20, and 24.
26 The AED discharge summary was not scanned into the record in cases 3, 5, and 7.
27 The scanning errors occurred in cases 20 and 26.
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EHRS, and the patient did not receive a notification letter. During
the on-site inspection, the supervisor reported that the provider was
not notified the report was available until one month later.
Clinician On-Site Inspection
We discussed health information management processes with health information
management supervisors, ancillary staff, nurses, and providers. According to
medical records supervisors, once the off-site specialty reports were scanned into
EHRS, CTF providers automatically received a notification through the EHRS
system to review the report.
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Compliance Testing Results
Table 9. Health Information Management
Table 9. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s
electronic health record within three calendar days of the encounter 20 0 12 100%
date? (4.001)
Are specialty documents scanned into the patient’s electronic health
23 7 15 76.7%
record within five calendar days of the encounter date? (4.002) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of 20 0 0 100%
hospital discharge? (4.003) *
During the inspection, were medical records properly scanned,
9 15 0 37.5%
labeled, and included in the correct patients’ files? (4.004) *
For patients discharged from a community hospital: Did the
preliminary or final hospital discharge report include key elements
20 0 0 100%
and did a provider review the report within five calendar days of
discharge? (4.005) *
Overall percentage (MIT 4): 82.8%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
Cycle 6, Correctional Training Facility | 33
TTaabbllee 1100.. OOtthheerr TTeessttss RReelalatteedd t too H Heeaaltlhth I nInfoformrmataiotino nM Manaangaegmeemnetnt
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse
9 1 0 90.0%
the radiology report within specified time frames? (2.002) *
Laboratory: Did the health care provider review and endorse the
10 0 0 100%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the provider acknowledge the STAT results, OR did
nursing staff notify the provider within the required time frame? N/A N/A N/A N/A
(2.008) *
Pathology: Did the institution receive the final pathology report within
8 2 0 80.0%
the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
6 2 2 75.0%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results of the
3 5 2 37.5%
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 10 5 0 66.7%
frame? (14.002) *
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required 8 7 0 53.3%
time frame? (14.005) *
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required 8 5 2 61.5%
time frame? (14.008) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Correctional Training Facility | 34
Recommendations
• Medical leadership should consider routinely assessing each
provider’s message center to ensure providers are timely reviewing
and endorsing diagnostic and specialty reports.
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Health Care Environment
Overall
Rating
In this indicator, OIG compliance inspectors tested clinics’ waiting areas,
infection control, sanitation procedures, medical supplies, equipment Inadequate
management, and examination rooms. Inspectors also tested clinics’ performance
Case Review
in maintaining auditory and visual privacy for clinical encounters. Compliance
Rating
inspectors asked the institution’s health care administrators to comment on their
facility’s infrastructure and its ability to support health care operations. The OIG (N/A)
rated this indicator solely on the compliance score, using the same scoring
Compliance
thresholds as in the Cycle 4 and Cycle 5 medical inspections. Our case review
Score
clinicians do not rate this indicator.
Inadequate
(57.5%)
Results Overview
For this indicator, CTF’s performance declined, compared with its performance
in Cycle 5. In the present cycle, multiple aspects of CTF’s health care
environment needed improvement: multiple clinics contained expired medical
supplies and improperly calibrated or nonfunctional equipment; emergency
medical response bag (EMRB) logs were missing staff verification or inventory
was not performed and treatment carts were missing log entries; and staff did not
regularly sanitize their hands before or after examining patients. These factors
resulted in an inadequate rating for this indicator.
Compliance Testing Results
Outdoor Waiting Areas
We examined outdoor
patient waiting areas (see
Photo 1). Health care and
custody staff reported
existing waiting areas had
sufficient seating capacity.
The staff reported the
outdoor waiting area was
only used when the indoor
waiting area was at
capacity. Staff also reported
that during inclement
weather, they only called
patients close to their
appointment time.
Photo 1. B North specialty clinic outdoor waiting area (photographed on
October 19, 2021).
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
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Indoor Waiting Areas
We inspected indoor waiting
areas (see Photo 2). Health
care and custody staff
reported existing waiting
areas contained sufficient
seating capacity. During our
inspection, we did not
observe overcrowding or
noncompliance with social
distancing requirements in
any of the clinics’ indoor
waiting areas.
Photo 2. North clinic indoor waiting area (photographed
on October 21, 2021).
Clinic Environment
Four of six clinic
environments were
sufficiently conducive to
medical care: they provided
reasonable auditory privacy,
appropriate waiting areas,
wheelchair accessibility, and
nonexamination room
workspace (MIT 5.109,
66.7%). In two clinic
environments, we observed
nursing staff providing
services to multiple patients
concurrently in the vital sign
check stations which did not
allow for auditory privacy
Photo 3. Multiple patients serviced at the same time in the triage station and
(see Photo 3). in close proximity to each other, which prohibited auditory privacy
(photographed on October 21, 2021).
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Of the nine clinics we observed, five
contained appropriate space,
configuration, supplies, and
equipment to allow clinicians to
perform proper clinical
examinations (MIT 5.110, 55.6%).
Two clinics had examination rooms
that lacked visual privacy when
conducting patient examinations
(see Photo 4). One clinic had
unsecured confidential medical
records. The remaining clinic’s
examination room lacked adequate
space (less than 100 square feet).
Photo 4. Examination rooms that lacked visual privacy
when conducting patient examinations (photographed on
October 21, 2021).
Clinic Supplies
Two of the nine clinics followed adequate
medical supply storage and management
protocols (MIT 5.107, 22.2%). We found one or
more of the following deficiencies in seven
clinics: expired medical supplies (see Photos 5
and 6), unidentified or mislabeled medical
supplies, compromised original medical
supply packaging, a disorganized medical
supply cabinet or drawer (see Photo 7, next
page), medical supplies stored directly on the
floor, or cleaning materials stored with
medical supplies.
Photo 5. Expired medical supplies dated March 2021
(photographed on October 20, 2021).
Photo 6. Expired
medical supplies dated
September 11, 2021
(photographed on
October 20, 2021).
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One of the nine clinics met
requirements for essential core
medical equipment and supplies
(MIT 5.108, 11.1%). The remaining
eight clinics lacked medical supplies
or contained improperly calibrated
or nonfunctional equipment. The
missing items included examination
table disposable paper and a peak
flow meter and tips. The improperly
calibrated or nonfunctional
equipment included a nebulizer,
weight scale, pulse oximeter, and
several nonfunctional oto-
ophthalmoscopes. We also found
unsanitary storage of tongue
Photo 7. Unlabeled and disorganized medical supplies;
depressors (see also Photo 7).
also of note: unsanitary storage of tongue depressors
stored in an open box with other supplies (photographed
on October 10, 2021).
We examined emergency medical
response bags (EMRBs) to determine
whether they contained all essential
items. We checked whether staff
inspected the bags daily and
inventoried them monthly. None of
the seven EMRBs we reviewed
passed our test (MIT 5.111, zero). We
found one or more of the following
deficiencies with six EMRBs: staff
failed to ensure that the EMRB’s
compartments were sealed and
intact, EMRBs contained oral
airways with compromised sterile
packaging (see Photo 8), and staff
had not inventoried the EMRBs
when the seal tags were replaced or
had not been opened in the last 30
days. In the remaining clinic, staff in
the OHU did not maintain the
treatment cart daily check sheet
(CDCR form 7544) and the
defibrillator performance test log
(CDCR form 7548). In addition, the
treatment cart contained previously
Photo 8. EMRB compromised oral airway sterile packaging sterilized reusable medical
(photographed on October 20, 2021). equipment stored beyond the
documented shelf life.
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
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Medical Supply Management
All the medical supply storage areas located outside the medical clinics stored
medical supplies adequately (MIT 5.106, 100%).
According to the chief executive officer (CEO), CTF expressed no concerns about
the medical supplies process. Health care managers and medical warehouse
managers expressed no concerns about the medical supply chain or their
communication process with the existing system.
Infection Control and Sanitation
Staff appropriately disinfected, cleaned, and sanitized six of eight clinics (MIT
5.101, 75.0%). In one clinic, we found examination room cabinets under the sink
had accumulated grime. In the remaining clinic, test strips used to show whether
the cleaning solution meets the proper sanitation level were expired.
Staff in six of eight clinics (MIT 5.102, 75.0%) properly sterilized or disinfected
medical equipment. In one clinic, staff did not date stamp and initial the
packaging of sterilized medical equipment. In another clinic, as part of their daily
cleaning protocol, staff relied on the incarcerated person porters to disinfect the
examination table prior to the start of their shift.
We found operating sinks and hand hygiene supplies in the examination rooms
of seven of nine clinics (MIT 5.103, 77.8%). However, patient restrooms in two
clinics lacked antiseptic soap.
We observed patient encounters in five clinics. In two clinics, clinicians did not
wash their hands before examining their patients, before applying gloves, after
performing blood draws, or before handling specimen vials (MIT 5.104, 60.0%).
Health care staff in eight of nine clinics followed proper protocols to mitigate
exposure to blood-borne pathogens and contaminated waste (MIT 5.105, 88.9%).
In one clinic, we found the sharps container overfilled.
Physical Infrastructure
CTF’s health care management and plant operations manager reported all
clinical area infrastructures were in good working order and did not hinder
health care services.
At the time of our medical inspection, the institution reported the health care
facility improvement program (HCFIP) project to renovate the Q Wing and the
specialty clinic spaces, designed to provide improvements in the quality of
patient care, was delayed due to the COVID-19 pandemic. CTF estimated
groundbreaking would occur in the first quarter of 2022, and the project would be
completed by the first quarter of 2023 (MIT 5.999).
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Compliance Testing Results
Table 11. Health Care Environment
Table 11. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately
6 2 1 75.0%
disinfected, cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable
invasive and noninvasive medical equipment is properly sterilized or 6 2 1 75.0%
disinfected as warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks
7 2 0 77.8%
and sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal
3 2 4 60.0%
hand hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to
8 1 0 88.9%
blood-borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the
medical supply management process adequately support the needs 1 0 0 100%
of the medical health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for
2 7 0 22.2%
managing and storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have
1 8 0 11.1%
essential core medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas
4 2 3 66.7%
conducive to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms
5 4 0 55.6%
conducive to providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency
crash carts inspected and inventoried within required time frames, 0 7 2 0
and do they contain essential items? (5.111)
Does the institution’s health care management believe that all clinical This is a nonscored test. Please
areas have physical plant infrastructures that are sufficient to provide see the indicator for discussion of
adequate health care services? (5.999) this test.
Overall percentage (MIT 5): 57.5%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Correctional Training Facility | 41
Recommendations
• To ensure that staff are following equipment and medical supply
management protocols, nursing leadership should consider
performing random spot checks.
• Medical leadership should remind staff to follow universal hand
hygiene precautions. Implementing random spot checks could
improve compliance.
• Nursing leadership should direct nurse supervisors at each clinic to
review the monthly emergency medical response bag (EMRB) and
treatment cart logs to ensure they are regularly inventoried and
sealed.
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Transfers
Overall
Rating
In this indicator, OIG inspectors examined the transfer process for those patients
Adequate
who transferred into the institution as well as for those who transferred to other
institutions. For newly arrived patients, our inspectors assessed the quality of
Case Review
health screenings and the continuity of provider appointments, specialist
Rating
referrals, diagnostic tests, and medications. For patients who transferred out of
Adequate
the institution, inspectors checked whether staff reviewed patient medical
records and determined the patient’s need for medical holds. They also assessed
Compliance
whether staff transferred patients with their medical equipment and gave correct
Score
medications before patients left. In addition, our inspectors evaluated the
Adequate
performance of staff in communicating vital health transfer information, such as
(80.0%)
preexisting health conditions, pending appointments, tests, and specialty
referrals; and inspectors confirmed whether staff sent complete medication
transfer packages to the receiving institution. For patients who returned from
off-site hospitals or emergency rooms, inspectors reviewed whether staff
appropriately implemented the recommended treatment plans, administered
necessary medications, and scheduled appropriate follow-up appointments.
Results Overview
CTF had a mixed performance in this indicator. Compared with Cycle 5, CTF’s
compliance score declined from 92.9 percent to 80.0 percent. However, our
clinicians found a similar number of deficiencies. As was seen in Cycle 5, CTF
performed well with ensuring newly arrived patients received their prescribed
medications. However, medications were not always administered to patients
who had brief layovers at CTF. Furthermore, our compliance and clinician teams
found that nurse assessments were not always complete for patients transferring
into the institution or returning from a community hospital. After reviewing the
compliance testing and case review results, we rated this indicator adequate.
Case Review and Compliance Testing Results
Our clinicians reviewed 18 cases in which patients transferred into or out of the
institution or returned from an off-site hospital or emergency room. We
identified 18 deficiencies, seven of which were significant.28
Transfers In
Both case review and compliance testing found room for improvement in nurses’
initial assessments of patients. Compliance testing revealed that CTF nurses did
not thoroughly complete initial health screening forms and did not always assess
patients when warranted (MIT 6.001, 40.0%). In one of the three cases our
clinicians reviewed, the nurse did not accurately document which medications
28 Deficiencies occurred in cases 1, 2, 11, 19–22, 28, 29, 30, and 59. Cases 2, 11, 19, 21, and 29 had
significant deficiencies.
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Cycle 6, Correctional Training Facility | 43
the patient was prescribed, did not address the diabetic patient’s sugar level, and
did not correctly document that the patient had coccidioidomycosis risk factors.
Our compliance team found CTF’s medication continuity was excellent for
patients at the time of transfer (MIT 6.003, 100%). Our clinicians found only one
significant medication deficiency:
• In case 28, the patient transferred into CTF, but did not receive two
of his chronic care medications for six days and another three of his
chronic care medications for 28 days.
Compliance testing found that when patients transferred into CTF with
preapproved specialty services, only 30.0 percent of specialty appointments were
completed within the required time frames (MIT 14.010). Our clinicians reviewed
one patient who transferred into the institution with a pending specialty
appointment and found he was evaluated by a specialist within the ordered time
frame.
Transfers Out
CTF’s transfer-out process was acceptable. Our clinicians reviewed three
transfer-out cases and identified three deficiencies.29 All deficiencies were
related to CTF’s failure to communicate with the transferring facility regarding
necessary specialist appointments. The following is an example:
• In case 32, the patient sustained a fracture on the day he transferred
from CTF. There was no documentation that a CTF nurse or provider
communicated this information with the receiving institution.
Fortunately, the receiving institution arranged a timely specialist
evaluation.
CTF’s transfer-out process was not observed by the compliance team because no
patients transferred out on the day of the OIG compliance on-site inspection
(MIT 6.101, N/A).
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at high
risk for lapses in care quality. These patients typically experienced severe illness
or injury. They require more care and place strain on the institution’s resources.
Also, because the patients have complex medical issues, successful health
information transfer is necessary for good quality care. Any transfer lapse can
result in serious consequences for these patients.
29 Deficiencies occurred once in case 33 and twice in case 32.
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
Cycle 6, Correctional Training Facility | 44
Our clinicians reviewed 19 events and found 12 deficiencies related to hospital or
emergency room after care, five of which were significant.30 Many of the
deficiencies were related to incomplete nursing assessments and care plans. The
following are some examples:
• In case 2, the patient returned to CTF after a community emergency
room evaluation. In the emergency room, the physician noted the
patient was paranoid and delusional. However, the CTF nurse did
not perform a mental health assessment or consult with a mental
health provider.
• In case 11, the patient returned to CTF after a 13-day community
hospital admission with a new diagnosis of metastatic cancer. The
nurse did not weigh the patient, did not assess the patient for pain,
and did not complete a thorough physical exam.
• In case 21, the patient returned to CTF after a three-day hospital
admission for a cardiac condition. The CTF nurse inappropriately
advised the patient to discontinue taking aspirin, which increased
the risk of harm to the patient.
CTF’s performance was excellent in retrieving and reviewing hospital records
(MIT 4.003 and MIT 4.005, 100%). Our clinicians reviewed 19 hospital or
emergency room returns and found three deficiencies.31 One deficiency was
considered significant when the provider did not endorse hospital records for 13
days.
Both our case review and compliance teams found CTF’s performance was
excellent in providing follow-up appointments within required time frames to
patients returning from the hospital and emergency room visits (MIT 1.007,
100%).
Compliance testing showed CTF’s performance was poor in medication
continuity (MIT 7.003, 40.0%). Similarly, our clinicians identified two occasions in
which the institution’s providers did not initiate medication as recommended at
the time hospital discharge.32 In addition, our clinicians identified a significant
deficiency in which medications were not issued to the patient as prescribed.33
Clinician On-Site Inspection
The OIG clinician met with the receiving and release (R&R) nurse, who was
knowledgeable about the transfer process and job duties. At the time of our
30 Deficiencies occurred in cases 1, 2, 11, 19-22, and 59. Significant deficiencies occurred in cases 2, 11,
19, and twice in case 21.
31 Deficiencies occurred in cases 2, 19, and 20. A significant deficiency occurred in case 19.
32 Deficiencies occurred in cases 21 and 59.
33 A significant deficiency occurred in case 21.
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
Cycle 6, Correctional Training Facility | 45
inspection, the R&R was staffed with a registered nurse on each shift. R&R nurses
evaluated patients arriving and transferring to other departmental institutions.
According to the R&R nurse, the central pharmacy reconciled all medications for
arriving patients. Although the R&R does not have an Omnicell machine, the
nurse explained that medications could be easily obtained in the triage and
treatment area (TTA) due to its proximity to R&R.34
Patients who returned from a community hospital or emergency room were
evaluated in the TTA. The TTA nurses reported that when patients return from a
higher level of care, providers reconcile medications.
34 An Omnicell is an automated medication dispensing machine.
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
Cycle 6, Correctional Training Facility | 46
Compliance Testing Results
TTaabbllee 1122.. TTrraannssffeerrss
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: Did nursing staff complete the initial health screening and
10 15 0 40.0%
answer all screening questions within the required time frame?
(6.001) *
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
disposition section of the initial health screening form; refer the
23 0 2 100%
patient to the TTA if TB signs and symptoms were present; and
sign and date the form on the same day staff completed the health
screening? (6.002)
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
13 0 12 100%
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the corresponding 0 0 0 N/A
transfer packet required documents? (6.101) *
Overall percentage (MIT 6): 80.0%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 13. Other Tests Related to Transfers
Table 13. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 22 3 0 88.0%
patient seen by the clinician within the required time frame? (1.002) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment with a primary care provider 20 0 0 100%
within the required time frame? (1.007) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of hospital 20 0 0 100%
discharge? (4.003) *
For patients discharged from a community hospital: Did the preliminary
or final hospital discharge report include key elements and did a
20 0 0 100%
provider review the report within five calendar days of discharge?
(4.005) *
Upon the patient’s discharge from a community hospital: Were all
ordered medications administered, made available, or delivered to the 8 12 0 40.0%
patient within required time frames? (7.003) *
Upon the patient’s transfer from one housing unit to another: Were
21 4 0 84.0%
medications continued without interruption? (7.005) *
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 3 7 0 30.0%
administered or delivered without interruption? (7.006) *
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at the
6 14 0 30.0%
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Correctional Training Facility | 48
Recommendations
• Nursing leadership should consider educating receiving and release
(R&R) nurses in the proper completion of initial health screening
questions.
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Medication Management
Overall
Rating
In this indicator, OIG inspectors evaluated the institution’s performance in
administering prescription medications on time and without interruption. The Inadequate
inspectors examined this process from the time a provider prescribed medication
Case Review
until the nurse administered the medication to the patient. When rating this
Rating
indicator, the OIG strongly considered the compliance test results, which tested
medication processes to a much greater degree than case review testing. In Adequate
addition to examining medication administration, our compliance inspectors also
Compliance
tested many other processes, including medication handling, storage, error
Score
reporting, and other pharmacy processes.
Inadequate
(67.1%)
Results Overview
CTF performed poorly overall in this indicator. CTF staff had difficulty ensuring
medication continuity in multiple areas. Similar to Cycle 5, patients who
transferred into the institution and returned from a community hospital did not
always receive their medications timely. Compliance testing found that patients
often did not receive their chronic care medications prior to exhaustion. When
patients had a layover at CTF, they frequently did not receive their medications.
Although our clinicians found medication management adequate, compliance
testing is a more encompassing approach in this indicator. Factoring in both
compliance testing and case reviews, we rated this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 39 cases related to medications and identified 20 medication
deficiencies, 12 of which were significant.35
New Medication Prescriptions
Compliance testing found that 80.0 percent of new medications were available or
administered timely (MIT 7.002). Our clinicians found three medication delays:36
• In case 11, the patient did not receive the newly prescribed
metoprolol and ondansetron for a month.37
• In case 17, the patient received the newly prescribed metoprolol
medication one month late.
35 Deficiencies occurred in cases 1, 6, 9, 10, 11, 12, 14, 17, 20, 21, 25, 27, 28, and 59. Cases 11, 12, 14, 17,
20, 21, 25, 27, 28, and 59 had significant deficiencies.
36 Deficiencies occurred in cases 6 and 20. Case 20 had a significant deficiency.
37 Metoprolol is a blood pressure medication. Ondansetron is a medication used for nausea and
vomiting.
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• In case 20, the patient received an antifungal medication one day
late, which resulted in two missed doses.
Chronic Medication Continuity
CTF performed poorly with ensuring medication continuity for chronic
conditions. Compliance testing found that patients did not receive their chronic
care medications within the required time frames (MIT 7.001, 20.0%). Our
clinicians identified 12 deficiencies, seven of which were considered significant.38
• In case 14, the diabetic patient did not receive his chronic care
diabetes medication for two months.
• In case 21, the patient did not receive two of his chronic care
medications for one month.
• In case 25, the patient was prescribed a daily dose of aspirin;
however, the patient did not receive the medication for one month.
Hospital Discharge Medications
CTF performed poorly in ensuring patients received their medications when they
returned from an off-site hospital or emergency room. Compliance testing
showed that when patients returned from an off-site hospital or emergency room,
they did not receive their medications within required time frames (MIT 7.003,
40.0%). Our clinicians reviewed 19 hospital returns and found one significant
deficiency.39 Please see the Transfers indicator for further details.
Specialized Medical Housing Medications
CTF’s medication management in the specialized medical housing was
acceptable. Compliance testing showed that when patients were admitted to the
outpatient housing unit (OHU), medications were administered timely 75.0
percent of the time (MIT 13.004). Our clinical team found two significant
deficiencies related to specialized medical housing.40 The following is an
example:
• In case 59, the patient returned from a community hospital and was
admitted to the OHU. There was no evidence the patient received
two of his prescribed medications after returning to CTF.
38 Deficiencies occurred in cases 1, 9, 12, 14, 17, 21, 25, and 27. Cases 12, 14, 17, 21, 25, and 27 had
significant deficiencies.
39 Significant deficiencies occurred in cases 11, 17, and 20.
40 Cases 27 and 59 had significant deficiencies.
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Transfer Medications
CTF scored very high in compliance testing of medication continuity for patients
transferring into the institution (MIT 6.003, 100%). Our clinicians identified one
significant medication deficiency for a patient arriving at CTF.41 Compliance
testing found good medication continuity when patients transferred within the
institution (MIT 7.005, 84.0%). However, CTF scored low in compliance testing of
medication continuity for patients who had had layovers at CTF (MIT 7.006,
30.0%).
Medication Administration
Compliance testing showed that 66.7 percent of TB medications were
administered timely (MIT 9.001). However, compliance testing also found that
nurses did not thoroughly monitor patients with prescribed TB medications
(MIT 9.002, zero).
Clinician On-Site Inspection
Our clinicians interviewed nurses, the pharmacist-in-charge (PIC), and other
pharmacy personnel and discussed cases in which our clinicians had questions
about specific medications. The PIC showed our clinicians evidence that many
medications were delivered to the medication administration areas, but agreed
there was no evidence that patients received these medications. We found both
the nurses and pharmacy staff knowledgeable about the medication process.
Nursing leadership indicated the pharmacist was available after hours when
urgent medication issues occurred.
Compliance Testing Results
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in seven of
eight clinic and medication line locations (MIT 7.101, 87.5%). In one location,
medication nurses could not describe the narcotic medication discrepancy
reporting process.
CTF appropriately stored and secured nonnarcotic medications in six of nine
clinic and medication line locations (MIT 7.102, 66.7%). In two locations, the
refrigerated medications did not have a designated area for medications to be
returned to pharmacy. In another location, medications were not stored in an
orderly manner, and the medication cart did not have enough space to avoid
crowding of medications.
Staff kept medications protected from physical, chemical, and temperature
contamination in seven of the nine clinic and medication line locations (MIT
41 Case 28 had a significant deficiency.
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7.103, 77.8%). In one location, staff did not store oral and topical medications
separately. In another location, staff did not consistently record room and
refrigerator temperatures.
Staff successfully stored valid, unexpired medications in five of the nine
applicable medication line locations (MIT 7.104, 55.6%). In three locations,
medication nurses failed to label the multiple-use medication, as required by
CCHCS policy. In another location, medication nurses did not discard a
previously opened single-use solution and instead stored it in the medication
room.
Nurses exercised proper hand hygiene and contamination control protocols in
four of six locations (MIT 7.105, 66.7%). In two locations, nurses neglected to
wash or sanitize their hands before donning gloves and before each subsequent
regloving.
Staff in four of six medication preparation and administration areas
demonstrated appropriate administrative controls and protocols (MIT 7.106,
66.7%). In one location, a medication nurse could not describe the process to
reconcile newly received medication and the medication administration record
(MAR) against the corresponding physician’s order. In another location,
medication nurses did not maintain unissued medications in their original
labeled packaging.
Staff in four of six medication areas used appropriate administrative controls and
protocols when distributing medications to their patients (MIT 7.107, 66.7%). In
one location, medication nurses did not disinfect the top of a previously opened
insulin vial prior to withdrawing the medication. In another location, medication
nurses inaccurately logged the daily glucometer quality control test results prior
to use.
Pharmacy Protocols
CTF’s pharmacy staff followed general security, organization, and cleanliness
management protocols in its pharmacy, and properly stored nonrefrigerated and
refrigerated medications, scoring 100 percent in these tests (MIT 7.108, MIT
7.109, and MIT 7.110).
The PIC did not correctly review monthly inventories of controlled substances in
the institution’s clinic and medication storage locations. The nurses present at
the time of the medication area inspection did not correctly complete several
medication area inspection checklists. In addition, the PIC did not correctly
complete several medication area inspection checklists (CDCR Form 7477) and
neglected to record names, signatures, or dates on several inventory records.
These errors resulted in a score of zero in this test (MIT 7.111).
We examined 25 medication error reports. The PIC timely or correctly processed
all 25 reports (MIT 7.112, 100%).
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Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our
inspectors also followed up on any significant medication errors found during
compliance testing. We do not score this test; we provide these results for
informational purposes only. At CTF, the OIG did not find any applicable
medication errors (MIT 7.998).
CTF did not have a restricted housing unit at the time of inspection (MIT 7.999).
Compliance On-Site Inspection
During our onsite inspection at the North B clinic, we observed medication
nurses and a custody officer stop an active medication administration line due to
a medical emergency in the housing unit. According to medication nurses, LVNs
assigned in the medication room are primarily responsible in responding to any
medical emergency. When the LVNs arrived at the scene, they determined that
the patient needed a higher level of care and waited for TTA RNs from the
Central clinic to arrive. Meanwhile, the RNs assigned to conduct face-to-face
appointments in the North B clinic continued their appointments and did not
provide support to the LVNs. The medication nurses reported that this process
has been in practice for several years, as instructed by their nursing leadership.
This practice may increase the risk of delay in time sensitive medications as well
as a delay in emergency patient care.
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Table 14. Medication Management
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Table 14. Medication Management
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Scored Answer
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Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required
time frames or did the institution follow departmental policy for refusals or 3 12 10 20.0%
no-shows? (7.001) *
Did health care staff administer, make available, or deliver new order
20 5 0 80.0%
prescription medications to the patient within the required time frames? (7.002)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 8 12 0 40.0%
required time frames? (7.003) *
For patients received from a county jail: Were all medications ordered by
the institution’s reception center provider administered, made available, or N/A N/A N/A N/A
delivered to the patient within the required time frames? (7.004) *
Upon the patient’s transfer from one housing unit to another: Were
21 4 0 84.0%
medications continued without interruption? (7.005) *
For patients en route who lay over at the institution: If the temporarily housed
patient had an existing medication order, were medications administered or 3 7 0 30.0%
delivered without interruption? (7.006) *
All clinical and medication line storage areas for narcotic medications: Does
the institution employ strong medication security controls over narcotic 7 1 2 87.5%
medications assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution properly secure and store nonnarcotic medications in the 6 3 1 66.7%
assigned storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution keep nonnarcotic medication storage locations free of 7 2 1 77.8%
contamination in the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does
the institution safely store nonnarcotic medications that have yet to expire in 5 4 1 55.6%
the assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ
and follow hand hygiene contamination control protocols during medication 4 2 4 66.7%
preparation and medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications 4 2 4 66.7%
for patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering 4 2 4 66.7%
medications to patients? (7.107)
Pharmacy: Does the institution employ and follow general security,
organization, and cleanliness management protocols in its main and remote 1 0 0 100%
pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
1 0 0 100%
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
1 0 0 100%
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
0 1 0 0
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting
25 0 0 100%
protocols? (7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the This is a nonscored test. Please
OIG find that medication errors were properly identified and reported by the see the indicator for discussion of
institution? (7.998) this test.
Pharmacy: For Information Purposes Only: Do patients in restricted housing This is a nonscored test. Please
units have immediate access to their KOP prescribed rescue inhalers and see the indicator for discussion of
nitroglycerin medications? (7.999) this test.
Overall percentage (MIT 7): 67.1%
* The OIG clinicians considered these compliance tests along with their case review findings when determining the
quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 15. Other Tests Related to Medication Management
Table 15. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
13 0 12 100%
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the corresponding 0 0 0 N/A
transfer-packet required documents? (6.101) *
Patients prescribed TB medication: Did the institution administer the
2 1 0 66.7%
medication to the patient as prescribed? (9.001) *
Patients prescribed TB medication: Did the institution monitor the
patient per policy for the most recent three months he or she was on 0 3 0 0
the medication? (9.002) *
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 3 1 0 75.0%
within required time frames? (13.004) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical and nursing leadership should ensure that chronic care,
hospital discharge, and en route patients receive their medications
timely and without interruption.
• Nursing leadership and the public health nurse should instruct
nursing staff to properly document the monitoring of patients taking
tuberculosis (TB) medications.
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Preventive Services
Overall
Rating
In this indicator, OIG compliance inspectors tested whether the institution
Inadequate
offered or provided cancer screenings, tuberculosis (TB) screenings, influenza
vaccines, and other immunizations. If the department designated the institution
Case Review
as high risk for coccidioidomycosis (valley fever), we tested the institution’s
Rating
performance in transferring out patients quickly. The OIG rated this indicator
(N/A)
solely according to the compliance score, using the same scoring thresholds as in
the Cycle 4 and Cycle 5 medical inspections. Our case review clinicians do not
rate this indicator. Compliance
Score
Inadequate
Results Overview (59.4%)
CTF had a mixed performance in preventive services. Staff performed well in
offering patients an influenza vaccine for the most recent influenza season and
offering colorectal cancer screening for all patients from ages 45 through 75.
However, they faltered in administering and monitoring patients who were
taking prescribed TB medications, screening patients annually for TB, and in
offering required immunizations for chronic care patients. We rated this
indicator inadequate.
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Compliance Testing Results
Table 16. Preventive Services
Table 16. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
2 1 0 66.7%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the
patient per policy for the most recent three months he or she was on 0 3 0 0
the medication? (9.002) †
Annual TB screening: Was the patient screened for TB within the last
13 12 0 52.0%
year? (9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the
22 3 0 88.0%
patient offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the
N/A N/A N/A N/A
patient offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was
N/A N/A N/A N/A
patient offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients?
4 4 17 50.0%
(9.008)
Are patients at the highest risk of coccidioidomycosis (valley fever)
N/A N/A N/A N/A
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 59.4%
* The OIG clinicians considered these compliance tests along with their case review findings when determining the
quality rating for this indicator.
† In April 2020, after our review but before this report was published, CCHCS reported adding the symptom of fatigue
into the electronic health record system (EHRS) PowerForm for tuberculosis (TB)-symptom monitoring.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership and the public health nurse should instruct
nursing staff to properly document the monitoring of patients taking
tuberculosis (TB) medications.
• Nursing leadership should consider developing and implementing
measures to ensure that nursing staff timely screen patients for TB.
• Medical leadership should determine the root cause of challenges
that prevent the timely provision of chronic care vaccinations.
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Nursing Performance
Overall
Rating
In this indicator, the OIG clinicians evaluated the quality of care delivered by the
Inadequate
institution’s nurses, including registered nurses (RNs), licensed vocational nurses
(LVNs), psychiatric technicians (PTs), and certified nursing assistants (CNAs).
Our clinicians evaluated nurses’ performance in making timely and appropriate Case Review
assessments and interventions. We also evaluated the institution’s nurses’ Rating
documentation for accuracy and thoroughness. Clinicians reviewed nursing Inadequate
performance in many clinical settings and processes, including sick call,
outpatient care, care coordination and management, emergency services, Compliance
specialized medical housing, hospitalizations, transfers, specialty services, and
Score
medication management. The OIG assessed nursing care through case review
(N/A)
only and performed no compliance testing for this indicator.
When summarizing overall nursing performance, our clinicians understand that
nurses perform numerous aspects of medical care. As such, specific nursing
quality issues are discussed in other indicators, such as Emergency Services,
Specialty Services, and Specialized Medical Housing.
Results Overview
At CTF, nursing care was insufficient. Unlike in Cycle 5, CTF nurses did not have
an experienced appointed leadership team. In this cycle, most members of the
leadership nursing team were serving in acting roles. The majority of significant
nursing deficiencies occurred when RNs did not make appropriate triage
decisions, did not perform thorough assessments, and did not monitor their
patients. In addition, we identified patterns of incomplete and missing nursing
documentation, and that most of the deficiencies were made by nurses working
in the TTA, nurses caring for COVID-19 patients, and nurses working in the
medical clinics. After considering all aspects of CTF’s nursing performance, the
OIG rated this indicator inadequate.
Case Review Results
We reviewed 216 nursing encounters in 53 cases. Of the nursing encounters we
reviewed, 122 were in the outpatient setting. We identified 91 nursing
performance deficiencies, 21 of which were significant.42
Nursing Assessment and Interventions
At CTF, we identified patterns of deficiencies for incomplete nursing
assessments and interventions. Most of the significant deficiencies were made by
nurses in the TTA and outpatient areas. However, we also identified several
42 Deficiencies occurred in cases 1–6, 8, 9, 11, 16, 17, 19-22, 24, 29, 32, 33, 25, 37, 29, 44, 45, 46, 50, 54,
58, and 59. Cases 1, 2, 4, 8, 9, 11, 20, 21, 29, 35, 38, and 59 had significant deficiencies.
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deficiencies when patients returned to the institution after a hospital or
emergency room visit. The following are examples:
• In case 8, this patient was isolated for a COVID-19 infection. The
nurse performing rounds noted that the patient’s oxygen saturation
result was very low. Despite the dangerously low oxygen level, the
nurse did not initiate oxygen, and did not assess the patient’s skin
and nail beds for changes in color. In addition, the nurse did not
listen to the patient’s lung sounds to ensure adequate oxygen
exchange.
• In case 9, this patient’s blood pressure was high. The patient
informed the licensed vocational nurse (LVN) that the patient had
stopped taking the KOP blood pressure medication because of
itching, which would normally require a clinical follow up.43 The
LVN did not consult a provider or initiate a follow-up appointment.
• In case 11, the nurse evaluated a quarantined patient who
complained of shortness of breath, but the nurse did not ask the
patient how often this occurred or when it first began. The nurse did
not recognize that this symptom could be associated with a COVID-
19 infection and perform a point-of-care test. In addition, the nurse
did not assess the patient’s blood pressure and pulse rate, and did not
consult a provider to discuss a plan of care.
• In case 19, the nurse evaluated the patient for pneumonia but did not
listen to the patient’s lungs for abnormal sounds.
• In case 22, the patient returned to CTF after an abdominal surgery
and hospitalization. The nurse did not auscultate the patient’s lungs
or listen for active bowel sounds.44
• In case 45, the nurse performing sick call did not obtain the patient’s
vital signs. In cases 9 and 44, the nurses also did not assess the
patient’s vital signs during clinical encounters.
Nursing Documentation
Complete and accurate documentation is an essential component of patient care.
Without proper documentation, health care staff may overlook changes in a
patient’s condition and assessing care quality becomes challenging. We identified
patterns of incomplete and inaccurate documentation at CTF. The following are
some examples:
43 KOP means keep on person.
44 Abdominal surgery places a person at an elevated risk of pneumonia and constipation.
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• In case 4, the patient was isolated for a COVID-19 infection. Nurses
administered medications to lower the patient’s fever, but did not
document the patient’s temperature in EHRS or the MAR.
• In case 9, the patient was isolated for a COVID-19 infection. The
nurse noted that the patient’s oxygen saturation level had decreased,
and the patient would be monitored. However, there was no
documentation that this monitoring occurred.
• In case 20, a nurse documented in the MAR that a medication was
not administered because the patient had died; however, the patient
had not died.
Nursing Sick Call
Our clinicians reviewed 41 sick call requests in 28 cases. Compared to Cycle 5,
CTF improved in reviewing sick call requests timely, and our clinicians found
that most patients were evaluated timely. However, we identified that nurses did
not always consult providers or initiate follow-up appointments when clinically
warranted. The following are examples:
• In case 17, the diabetic patient had a foot wound; however, the nurse
did not consult a provider or initiate an urgent appointment.45
• In case 21, this patient had concerns of cardiac disease and was
awaiting a cardiac test. The nurse documented that the patient had
new lower extremity edema, which can be sign of heart disease, but
did not consult a provider.
Emergency Services
We identified patterns of poor triage decisions, incomplete nursing assessments
and interventions, and incomplete or missing nursing documentation. Of the 19
deficiencies identified, seven were significant. See the Emergency Services
indicator for more details.
Hospital Returns
We reviewed 12 cases involving patients who returned from a community
hospital or emergency room and identified seven nursing deficiencies. Most
deficiencies were related to incomplete nursing assessments. See the Transfers
indicator for more details.
45 Diabetic patients may have impaired circulation that can cause a delay in wound healing.
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Transfers
We reviewed six cases and found that when patients transferred out of CTF to
another institution, nurses did not inform the receiving institution of specialty
appointments in their documentation. Furthermore, when patients arrived to
CTF, nurses did not always perform thorough initial health screening
assessments or accurately document their findings. Additional information can
be found in the Transfers indicator.
Specialized Medical Housing
Case reviewers evaluated five OHU cases and found 11 nursing deficiencies, two
of which were significant. Please refer to the Specialized Medical Housing
indicator for more details.
Specialty Services
Nurses provided good care for patients returning from an off-site specialty
appointment. Most nurses performed appropriate assessments, reviewed
specialist recommendations, and communicated pertinent information to the
providers. The Specialty Services indicator provides further information.
Medication Management
Our clinicians reviewed 150 events involving medication management and
administration and identified 20 deficiencies, 12 which were significant. During
our on-site inspection, the pharmacy department was able to show that on
several occasions, medications were delivered to the medication administration
areas. However, there was no evidence that the patient received the medication.
The Medication Management indicator provides further information.
Clinician On-Site Inspection
During our on-site inspection, our clinicians toured the TTA, R&R, OHU, the
COVID-19 quarantine and isolation area, and the medical clinics. We met with
medical executives, nursing supervisors, medical staff, and custody staff.
Our clinicians met with CTF’s COVID-19 crisis team, who discussed their
pandemic operations. They explained that the institution’s COVID-19 outbreak
occurred between October and December 2020. Custody and medical staff
reported they had faced challenges during the outbreak including ensuring
sufficient staffing levels. At the time of our inspection, CTF’s housed both
isolation and quarantined patients in the central facility, which had 56 cells, each
with solid doors. Staff reported that they housed COVID-19 patients on the
second floor and quarantined patients on the first floor. Oxygen was stored
within the housing unit. The institution’s two dormitory-style housing units were
located in its North facility.
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We were informed of a high COVID-19 vaccination compliance rate (93%–95%).
The CEO indicated that when patients refused a COVID-19 vaccination, the
public health nurse or designee would meet with the patient to learn the reason
and address any concerns related to the vaccination. According to the medical
team, this extra step had a positive impact on CTF’s vaccination compliance.
Nursing leadership faced many challenges during the institution’s COVID-19
surge and expressed that staffing shortages had been challenging. The acting
CNE was not present during the onsite inspection, and we were informed that
this individual had been away for several months. However, the acting director of
nursing (DON) was present during our interview and had covered this position
for several months. In addition to the acting CNE and DON, there were three
acting supervising registered nurses (SRN). CTF had a total of four SRN vacancies
as well as 3.8 RN vacancies. The entire nursing team was pleasant and
accommodating during our inspection.
Our clinician and the CTF nursing leadership team discussed our case review
questions. Although the DON had reviewed and prepared written responses to
our questions, some of the nursing supervisors were not familiar with the cases
and did not always agree with the DON’s responses. Our clinician appreciated
the collaborative discussions.
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Recommendations
• The department should consider strategies to improve recruitment
and retention of nursing leadership and staff.
• Nursing executive leadership should ensure that nursing supervisors
who are conducting clinical care reviews identify opportunities for
improvement.
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Provider Performance
Overall
Rating
In this indicator, OIG case review clinicians evaluated the quality of care
Inadequate
delivered by the institution’s providers: physicians, physician assistants, and
nurse practitioners. Our clinicians assessed the institution’s providers’
performance in evaluating, diagnosing, and managing their patients properly. We Case Review
examined provider performance across several clinical settings and programs, Rating
including sick call, emergency services, outpatient care, chronic care, specialty Inadequate
services, intake, transfers, hospitalizations, and specialized medical housing. We
assessed provider care through case review only and performed no compliance Compliance
testing for this indicator. Score
(N/A)
Results Overview
CTF providers generally delivered poor care due to their decision-making,
emergency care, and diabetes care. Furthermore, emergency provider deficiencies
were not recognized, compounding this issue. While some areas, such as hospital
return care and hypertension care improved compared with Cycle 5, decision-
making, particularly in emergency and chronic care, continued to be problematic.
The OIG rated this indicator inadequate.
Case Review Results
In our inspection, we reviewed 110 provider events and identified 30
deficiencies.46 Of these deficiencies, 21 were significant.47 In addition, the OIG
clinicians examined the care quality in 22 comprehensive case reviews and found
18 adequate and four inadequate.
Assessment and Decision-Making
We identified several issues in provider assessments and decision-making. The
providers did not always perform assessments such as clinically relevant
examinations.48 CTF providers made questionable decisions, particularly in
emergency care and chronic care. The following are some examples:
• In case 2, the patient had a lab test for bilirubin, which was
elevated.49 The provider reviewed this elevated bilirubin result, but
sent a letter to the patient that the result was normal and did not
follow the bilirubin or discuss this with the patient. On site, the
46 Deficiencies occurred in cases 1, 2, 8, 10, 14, 15, 16, 17, 19, 21, 23, 24, 27, 32 and 59.
47 Significant provider deficiencies occurred in cases 1, 2, 8, 10, 14-17, 19, 21, 23, 24, 27, and 59.
48 Deficiencies occurred in cases 16, 17, and 21.
49 Bilirubin is a chemical made by the liver. An increased level may indicate liver, gallbladder, or
biliary tract disease.
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provider suggested the patient had Gilbert Syndrome, but we could
not find a documented history of this diagnosis as of the interview.50
• In case 16, the patient with psoriatic arthritis had been off his
medication for three months. The dermatologist recommended
monitoring the patient for signs of relapse and to consider restarting
the medication, if needed. However, the primary care provider did
not examine the patient’s skin for rash or joints.
• In case 17, the patient complained of bilateral foot pain during a
chronic care appointment; however, provider did not perform an
examination of the patient’s feet.
• In case 21, the patient had an elevated liver enzymes from
simvastatin, for which the hospitalist recommended rosuvastatin;
however, the provider on call did not start the patient on any statin
and did not document the reason why.51
• In case 23, the provider started the patient on scheduled morphine
for arthritis, but did not consider other therapies, monitor
effectiveness, indicate the goals of therapy, or plan the duration of
the patient’s opioid therapy.
Review of Records
Review of records is an important facet of provider care and thoroughness in this
area will allow for the best decisions for the patients. The providers generally
reviewed medical records carefully. We identified a few lapses in the following
cases:
• In case 10, the provider did not review that the patient had an
elevated hemoglobin A1c and did not optimize the patient’s blood
sugar control.52 This was unfortunate because the patient was going
to have surgery and better sugar management would reduce
complications from surgery and aid healing. During the on-site
inspection, the provider agreed that it was an oversight.
• In case 21, the patient had a heart attack. The primary care provider
followed up with the patient after the hospitalization, but did not
order the rosuvastatin and liver enzyme laboratory tests that were
recommended.53 During the on-site inspection, the provider verbally
50 Gilbert syndrome is a condition where the liver does not process the bilirubin properly, resulting in
an elevated bilirubin level.
51 Statin is a cholesterol reducing medication. Rosuvastatin and simvastatin are both statin
medications, but rosuvastatin can be used in patients with elevated liver enzymes.
52 The hemoglobin A1c is a test used to monitor and assess a patient’s diabetic sugar control.
53 Rosuvastatin is a cholesterol reducing medication and secondary prevention for heart disease such
as a heart attack.
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admitted he was distracted by the patient’s cellulitis and missed the
recommendation.
Emergency Care
Appropriate and timely decision-making, prompt evaluation and assessment, and
stabilization of heart and lung function are critical in an urgent or emergent
situation. Providers managed patients poorly in the TTA. We found problems
with the provider’s decisions in the following cases:
• In case 17, the patient had chest pain. The TTA nurse contacted the
provider about the patient; however, the provider requested a nurse
follow-up instead of seeing the patient or ordering a provider follow-
up. Providers need to see patients during or after a TTA evaluation to
ensure patients have the proper diagnosis and treatment plans.
• In case 19, the provider sent the patient, who had low oxygen levels,
to the hospital with a state car instead of an ambulance. This placed
the patient at increased risk of complications during patient
transport.
• In case 21, a patient had cardiac risk factors and a recent cardiac
stress test that indicated reduced blood flow to a portion of the heart.
He had also complained of chest pain and shortness of breath. The
provider sent the patient back to housing instead of transferring him
to the hospital.
Chronic Care
Chronic care appointments are an important component of provider care. These
appointments allow providers to review the patient’s chronic medical issues to
determine whether symptoms and physical findings have changed and whether
management needs to be modified. In several cases, the providers had chances to
improve diabetes care, but did not utilize the opportunities:
• In case 8, the provider recognized worsening blood sugar control and
only recommended the same diet that he recommended three
months prior. During the on-site inspection, the provider explained
that the provider was expecting the results for the hemoglobin A1c
in a few days to make a decision on further changes. However, the
patient passed away two months later without a provider
appointment or therapy modification.
• In case 14, the provider decided not to modify the patient’s diabetes
therapy because he erroneously documented that the patient’s
medication had recently been adjusted; however, it was adjusted
about 10 months prior. During the on-site inspection, the provider
reported that he had not reviewed when the therapy was last
modified.
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Specialty Services
Providers appropriately referred patients for specialty consultation when needed.
Providers also followed up with patients after specialty appointments and
generally carried out recommendations from the specialists. However, case
reviewers identified a deficiency where this did not happen.
• In case 27, the provider did not order the imaging study that the
specialist recommended.
We discuss providers’ specialty performance further in the Specialty Services
indicator.
Documentation Quality
CTF documentation had room for improvement. Our clinicians identified two
deficiencies in which the provider on call did not document a note after being
notified by the TTA RN. In two of the three specialized medical housing cases we
reviewed, we found that the provider copied and pasted his physical exam from
an earlier note.
• In case 27, the provider’s physical exam of the patient was an exact
copy from a previous appointment. Accurate serial exams were
extremely important in this case because the patient had worsening
weakness and progressive degradation of his leg muscles.
Provider Continuity
The OIG clinicians did not find any problems with provider continuity in the
cases reviewed.
Clinician On-Site Inspection
We observed an efficient morning huddle in which pertinent information was
distributed within the primary care team. The providers reported good working
relationships with nurses, custody, and other providers. According to providers,
they support medical leadership and receive appropriate feedback.
We discussed provider deficiencies with medical leadership and providers. We
discussed the deficiency in case 21 with medical leadership, who supported the
provider’s decision-making and did not feel that the patient at risk of a heart
attack needed to be sent out to the hospital.
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Recommendations
• To improve provider decision-making, medical leadership should
consider including a review of emergency care when completing
annual provider reviews.
• Medical leadership should remind providers to assess pertinent
physical findings for patient medical issues and document patient
encounters appropriately.
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Specialized Medical Housing
Overall
Rating
In this indicator, OIG inspectors evaluated the quality of care in the specialized
Adequate
medical housing units. We evaluated the performance of the medical staff in
assessing, monitoring, and intervening for medically complex patients requiring
Case Review
close medical supervision. Our inspectors also evaluated the timeliness and
Rating
quality of provider and nursing intake assessments and care plans. We assessed
Adequate
staff members’ performance in responding promptly when patients’ conditions
deteriorated, and we looked for good communication when staff consulted one
Compliance
another while providing continuity of care. Our clinicians also interpreted
Score
relevant compliance results and incorporated them into this indicator. At the
Proficient
time of our inspection, CTF's specialized medical housing consisted of an
(87.5%)
outpatient housing unit (OHU).
Results Overview
CTF staff delivered good patient care in the OHU. Nurses took care of patients
timely and appropriately with minimal lapses in care. Medication administration
was acceptable. Provider performance in the OHU was good, except for several
instances of cloned documentation of physical exams. After reviewing the
different aspects of care in the OHU, we rated this indicator adequate.
Case Review and Compliance Testing Results
We reviewed five OHU cases, which included 24 provider events and 34 nursing
events.54 Because of the care volume that occurs in specialized medical housing
units, each provider and nursing event represents up to one month of provider
care and two weeks of nursing care. We identified 16 deficiencies, six of which
were significant.55
Provider Performance
CTF OHU providers performed well. Compliance testing showed that providers
completed admission history and physicals timely (MIT 13.002, 100%). Case
review clinicians one decision-making deficiency and several instances of
physical exams that were copied from previous appointments:
• In case 27, on several occasions, the provider documented the same
physical exam from the patient’s previous appointment. Because the
patient was suffering progressive weakness and loss of his leg
muscles, the physical exams should have reflected these changes.
54 The five OHU cases were cases 19, 20, 27, 58, and 59.
55 Deficiencies occurred in cases 19, 20, 27, 58, and 59. Cases 20, 27, and 59 had significant
deficiencies.
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When asked about this during our on-site inspection, the CME
agreed that the provider should have performed the examinations.
• In case 59, the patient with a recent cardiac stent placement
complained of chest pain. The provider noted the complaint and
patient’s history but did not order a cardiology follow-up
appointment. Because the patient had his cardiac procedure less
than a month prior, the medical standard would necessitate the
patient follow-up with a cardiologist after the medical procedure,
especially within a month of a cardiac stent placement.
Nursing Performance
Compliance testing showed OHU nurses completed 75.0 percent of initial
assessments within required time frames (MIT 13.001). Our clinicians found that
OHU nurses performed timely admission assessments and conducted rounds on
patients. Our clinicians identified 11 deficiencies related to nursing care, two of
which were significant.56
• In case 20, the nurses did not change the dressing on the patient’s
hand and central line as required.57
• In case 59, the patient had low blood pressure and bleeding at a
surgical site. The nurse did not recheck the patient's blood reassess
the site to ensure the bleeding had stopped, and the patient’s blood
pressure was not rechecked for 11 hours.
Medication Administration
Compliance testing showed 75.0 percent of newly admitted patients received
their medications within the required time frames (MIT 13.004). Our clinicians
found two deficiencies related to medication management; both were considered
significant.58 We discuss these deficiencies in more detail in the Medication
Management indicator.
Clinician On-Site Inspection
At CTF, the OHU was in the central building, near the TTA. The OHU had 17
medically designated beds and four alternative-housing beds. Four beds were in
two of the medical rooms, and another room had five beds. All remaining rooms
56 Deficiencies occurred in cases 19, twice in cases 58 and 59, and six times in case 20. Significant
deficiencies occurred in cases 20 and 59.
57 A central line is a catheter that is inserted into a large vein in the neck, chest, or groin to deliver
medication, fluids, or nutrition.
58 Significant deficiencies occurred in cases 27 and 59.
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were for single-person use. Our compliance onsite testing found the call light
system functional (MIT 13.101, 100%).
The OHU was staffed with an RN on second shift, and an LVN on other shifts.
According to staff, an RN from the TTA comes to the OHU at least once on the
first and third shifts and as needed. RN visits are recorded in an OHU logbook.
We also learned that on September 9, 2021, the CNE implemented new OHU
nursing expectations. A memorandum instructed the OHU nurses to perform a
complete skin assessment for each patient admitted to the OHU. Nurses were
also instructed to perform focused assessments each day and update care plans
weekly.
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Compliance Testing Results
Table 17. Specialized Medical Housing
Table 17. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Prior to 4/2019: Did the registered
nurse complete an initial assessment of the patient on the day of
admission, or within eight hours of admission to CMF’s Hospice? 3 1 0 75.0%
Effective 4/2019: Did the registered nurse complete an initial
assessment of the patient at the time of admission? (13.001) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time 4 0 0 100%
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior
to 4/2019): Did the primary care provider complete the Subjective,
Objective, Assessment, and Plan notes on the patient at the 0 0 4 N/A
minimum intervals required for the type of facility where the patient
was treated? (13.003) *,†
Upon the patient’s admission to specialized medical housing: Were
all medications ordered, made available, and administered to the 3 1 0 75.0%
patient within required time frames? (13.004) *
For OHU and CTC only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
1 0 0 100%
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells? (13.101) *
For specialized health care housing (CTC, SNF, Hospice, OHU):
Do health care staff perform patient safety checks according to
0 0 1 N/A
institution’s local operating procedure or within the required time
frames? (13.102) *
Overall percentage (MIT 13): 87.5%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still have
state-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should consider reminding OHU providers to
perform appropriate physical exams and document findings
accurately.
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Specialty Services
Overall
Rating
In this indicator, OIG inspectors evaluated the quality of specialty services. The
Adequate
OIG clinicians focused on the institution’s performance in providing needed
specialty care. Our clinicians also examined specialty appointment scheduling,
Case Review
providers’ specialty referrals, and medical staff’s retrieval, review, and
Rating
implementation of any specialty recommendations.
Adequate
Results Overview Compliance
Score
Inadequate
CTF provided acceptable specialty services for their patients. Staff appropriately
(73.7%)
ordered and provided access to specialists. Nurses evaluated all patients who
returned from specialty appointments, but CTF staff often did not retrieve
reports timely or did not ensure the timeliness of provider endorsements.
However, providers generally followed specialists’ recommendations timely. After
considering these factors, we rated this indicator adequate.
Case Review and Compliance Testing Results
We reviewed 68 events related to specialty services; 51 were specialty
consultations and procedures. We found 24 deficiencies in this category, 16 of
which were significant.59
Access to Specialty Services
CTF staff ensured good access to specialty services. Compliance testing showed
good access for routine-priority, medium-priority, and high-priority specialty
appointment requests ordered by CTF providers (MIT 14.007, 80.0%; MIT14.004,
93.3%; and MIT 14.001, 80.0%, respectively), but poor access to specialists for
requests ordered prior to transfer into the institution (MIT 14.010, 30.0%). Case
review clinicians also found good specialty access, but identified two access
deficiencies as show below:
• In case 26, a patient with spinal stenosis had his request for service
with the neurosurgeon denied.60 No provider discussed the denial
with the patient, and there was no record of a plan regarding the
patient’s spinal stenosis in the EHRS.
• In case 58, the pulmonologist evaluated a patient who had a fungal
lung infection and recommended a CT scan to look for evidence of
cancer, lung function tests, and a follow-up appointment in one
month to evaluate the possible cancer. However, these tests were not
59 Specialty deficiencies were found in cases 8, 9, 13, 16, 20, 21, 22, 23, 24, 26, 27, and 58. Significant
deficiencies were found in cases 8, 13, 21, 23, 24, 26, 27, and 58.
60 Spinal stenosis is a medical condition where the spinal column narrows and compresses on the
spinal cord. This may cause pain and disability.
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ordered until nine months later. Some factors that led to this
significant delay were different providers caring for the patient
during this time period, and the COVID-19 pandemic reducing
specialist availability.
Provider Performance
The providers generally ordered specialty consultations with clinically
appropriate time frames. After the consultation, providers followed up with
patients when clinically necessary. Compliance testing found that providers
usually saw patients within five days of a high-priority specialty consultation
(MIT 1.008, 85.7%). During case review, we found the following exception:
• In case 27, the neurosurgeon requested an MRI of the patient’s
cervical spine. However, the provider did not put in the request until
the neurosurgeon requested it a second time. Furthermore, the
provider did not order the neurosurgery follow-up after reviewing
the patient’s MRI results. A subsequent provider had to order the
follow-up.
Nursing Performance
CTF’s nursing performance with specialty services was good. Nurses properly
performed evaluations and complete assessments for patients returning from
specialty appointments. Case reviewers identified only two minor deficiencies.
Health Information Management
CTF staff did not retrieve specialty reports within required time frames or
consistently and timely obtain provider reviews and endorsements. Compliance
testing showed poor performance with retrieval of routine-priority (MIT 14.008,
61.5%), medium-priority (MIT 14.005, 53.3%), and high-priority (MIT 14.002,
66.7%) reports. Scanning performance of specialty reports was poor as well (MIT
4.002, 76.7%) Case review clinicians found two deficiencies with retrieving
specialty reports and also identified 12 deficiencies in which providers endorsed
reports late or not at all.
Clinician On-Site Inspection
During our on-site inspection, clinicians met with nurses and office staff from
the specialty department who were knowledgeable and answered our questions
concerning specific patients. Staff reported that most specialists continued to
evaluate patients and that CTF frequently utilized telemedicine providers during
the institution’s COVID-19 outbreak. According to staff, if a specialist
appointment could not be completed within the ordered time frame, the provider
would determine whether the service was still needed. Staff explained that some
appointments were cancelled and providers were tasked with reordering
necessary appointments.
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Compliance Testing Results
Table 18. Specialty Services
Table 18. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 12 3 0 80.0%
Request for Service? (14.001) *
Did the institution receive and did the primary care provider review
the high-priority specialty service consultant report within the 10 5 0 66.7%
required time frame? (14.002) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 9 1 5 90.0%
provider? (14.003) *
Did the patient receive the medium-priority specialty service within
15-45 calendar days of the primary care provider order or Physician 14 1 0 93.3%
Request for Service? (14.004) *
Did the institution receive and did the primary care provider review
the medium-priority specialty service consultant report within the 8 7 0 53.3%
required time frame? (14.005) *
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary care 11 0 4 100%
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 12 3 0 80.0%
Request for Service? (14.007) *
Did the institution receive and did the primary care provider review
the routine-priority specialty service consultant report within the 8 5 2 61.5%
required time frame? (14.008) *
Did the patient receive the subsequent follow-up to the routine-
priority specialty service appointment as ordered by the primary care 3 3 9 50.0%
provider? (14.009) *
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at the
6 14 0 30.0%
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
Did the institution deny the primary care provider’s request for
19 1 0 95.0%
specialty services within required time frames? (14.011)
Following the denial of a request for specialty services, was the
patient informed of the denial within the required time frame? 17 3 0 85.0%
(14.012)
Overall percentage (MIT 14): 73.7%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 19. Other Tests Related to Specialty Services
Table 19. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up
30 5 10 85.7%
visits occur within required time frames? (1.008) *, †
Are specialty documents scanned into the patient’s electronic health
23 7 15 76.7%
record within five calendar days of the encounter date? (4.002) *
* The OIG clinicians considered these compliance tests along with their own case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician
follow-up visits following most specialty services. As a result, we test 1.008 only for high-priority specialty
services or when the staff orders PCP or PC RN follow-ups. The OIG continues to test the clinical
appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should ensure that providers review and endorse
specialty reports timely.
• Medical leadership should ensure that the institution receives
specialty reports timely.
• Medical leadership should ensure that patients receive routine
specialty follow-up appointments timely.
• Medical leadership should ensure that patients who recently
transferred into the institution receive their previously scheduled
specialty appointments within the required time frames.
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Administrative Operations
Overall
Rating
In this indicator, OIG compliance inspectors evaluated health care
Proficient
administrative processes. Our inspectors examined the timeliness of the medical
grievance process and checked whether the institution followed reporting
Case Review
requirements for adverse or sentinel events and patient deaths. Inspectors
Rating
checked whether the Emergency Medical Response Review Committee (EMRRC)
(N/A)
met and reviewed incident packages. We investigated and determined whether
the institution conducted the required emergency response drills. Inspectors also
assessed whether the Quality Management Committee (QMC) met regularly and Compliance
addressed program performance adequately. In addition, our inspectors Score
determined whether the institution provided training and job performance Proficient
(90.8%)
reviews for its employees. We checked whether staff possessed current, valid
professional licenses, certifications, and credentials. The OIG rated this indicator
solely based on the compliance score, using the same scoring thresholds as in the
Cycle 4 and Cycle 5 medical inspections. Our case review clinicians do not rate
this indicator.
Because none of the tests in this indicator affected clinical patient care directly
(it is a secondary indicator), the OIG did not consider this indicator’s rating when
determining the institution’s overall quality rating.
Results Overview
CTF performed well in this indicator and scored high in most applicable tests.
However, one area showed room for improvement. Compliance testing revealed
the institution’s EMMRC was using incomplete checklists and did not timely
review cases. These findings are set forth in the table on the next page. We rated
this indicator proficient.
Nonscored Results
At CTF, the OIG did not have any applicable adverse sentinel events requiring
root cause analysis during our inspection period (MIT 15.001).
We obtained CCHCS Death Review Committee (DRC) reporting data. Five
unexpected (Level 1) and five expected (Level 2) deaths occurred during our
review period. In our inspection, the DRC did not complete any death review
reports promptly. The DRC finished five reports 22 to 182 days late, and
submitted the reports to the institution’s CEO 15 to 175 days. The remaining five
reports were overdue at the time of OIG’s inspection (MIT 15.998).
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Compliance Testing Results
Table 20. Administrative Operations
Table 20. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the
N/A N/A N/A N/A
institution meet RCA reporting requirements? (15.001) *
Did the institution’s Quality Management Committee (QMC) meet
6 0 0 100%
monthly? (15.002)
For Emergency Medical Response Review Committee (EMRRC)
reviewed cases: Did the EMRRC review the cases timely, and did
0 12 0 0
the incident packages the committee reviewed include the required
documents? (15.003)
For institutions with licensed care facilities: Did the Local Governing
Body (LGB) or its equivalent meet quarterly and discuss local N/A N/A N/A N/A
operating procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during
each watch of the most recent quarter, and did health care and 3 0 0 100%
custody staff participate in those drills? (15.101)
Did the responses to medical grievances address all of the inmates’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial inmate death reports
10 0 0 100%
to the CCHCS Death Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance
9 1 0 90.0%
appraisals timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 12 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR),
Basic Life Support (BLS), and Advanced Cardiac Life Support (ACLS) 2 0 1 100%
certifications? (15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy 5 0 2 100%
maintain a valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
1 0 0 100%
Agency (DEA) registration certificates? (15.109)
Did nurse managers ensure their newly hired nurses received the
1 0 0 100%
required onboarding and clinical competency training? (15.110)
This is a nonscored test. Please
Did the CCHCS Death Review Committee process death review
refer to the discussion in this
reports timely? (15.998)
indicator.
This is a nonscored test. Please
What was the institution’s health care staffing at the time of the OIG
refer to Table 4 for CCHCS-
medical inspection? (15.999)
provided staffing information.
Overall percentage (MIT 15): 90.8%
* Effective March 2021, this test was for informational purposes only.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should ensure that the institution’s Emergency
Medical Response Review Committee (EMRRC) review cases timely
and include all required documents.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to
review CCHCS policies and procedures, relevant court orders, and guidance
developed by the American Correctional Association. We also reviewed
professional literature on correctional medical care; reviewed standardized
performance measures used by the health care industry; consulted with clinical
experts; and met with stakeholders from the court, the receiver’s office, the
department, the Office of the Attorney General, and the Prison Law Office to
discuss the nature and scope of our inspection program. With input from these
stakeholders, the OIG developed a medical inspection program that evaluates the
delivery of medical care by combining clinical case reviews of patient files,
objective tests of compliance with policies and procedures, and an analysis of
outcomes for certain population-based metrics.
We rate each of the quality indicators applicable to the institution under
inspection based on case reviews conducted by our clinicians or compliance tests
conducted by our registered nurses. Figure A–1 below depicts the intersection of
case review and compliance.
Figure A-1. Inspection Indicator Review Distribution for CTF
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the
recommendation of its stakeholders, which continues in the Cycle 6 medical
inspections. Below, Table A–1 provides important definitions that describe this
process.
Table A–1. Case Review Definitions
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The OIG eliminates case review selection bias by sampling using a rigid
methodology. No case reviewer selects the samples he or she reviews. Because
the case reviewers are excluded from sample selection, there is no possibility of
selection bias. Instead, nonclinical analysts use a standardized sampling
methodology to select most of the case review samples. A randomizer is used
when applicable.
For most basic institutions, the OIG samples 20 comprehensive physician review
cases. For institutions with larger high-risk populations, 25 cases are sampled.
For the California Health Care Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected institution
and from CCHCS. Our analysts then apply filters to identify clinically complex
patients with the highest need for medical services. These filters include patients
classified by CCHCS with high medical risk, patients requiring hospitalization or
emergency medical services, patients arriving from a county jail, patients
transferring to and from other departmental institutions, patients with
uncontrolled diabetes or uncontrolled anticoagulation levels, patients requiring
specialty services or who died or experienced a sentinel event (unexpected
occurrences resulting in high risk of, or actual, death or serious injury), patients
requiring specialized medical housing placement, patients requesting medical
care through the sick call process, and patients requiring prenatal or postpartum
care.
After applying filters, analysts follow a predetermined protocol and select
samples for clinicians to review. Our physician and nurse reviewers test the
samples by performing comprehensive or focused case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the clinicians
review medical records, they record pertinent interactions between the patient
and the health care system. We refer to these interactions as case review events.
Our clinicians also record medical errors, which we refer to as case review
deficiencies.
Deficiencies can be minor or significant, depending on the severity of the
deficiency. If a deficiency caused serious patient harm, we classify the error as an
adverse event. On the next page, Figure A–2 depicts the possibilities that can lead
to these different events.
After the clinician inspectors review all the cases, they analyze the deficiencies,
then summarize their findings in one or more of the health care indicators in this
report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and compliance
inspectors. Analysts follow a detailed selection methodology. For most
compliance questions, we use sample sizes of approximately 25 to 30. Figure A–3
below depicts the relationships and activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT)
questions to determine the institution’s compliance with CCHCS policies and
procedures. Our nurse inspectors assign a Yes or a No answer to each scored
question.
OIG headquarters nurse inspectors review medical records to obtain information,
allowing them to answer most of the MIT questions. Our regional nurses visit
and inspect each institution. They interview health care staff, observe medical
processes, test the facilities and clinics, review employee records, logs, medical
grievances, death reports, and other documents, and obtain information
regarding plant infrastructure and local operating procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for each of the
questions applicable to a particular indicator, then averages the scores. The OIG
continues to rate these indicators based on the average compliance score using
the following descriptors: proficient (85.0 percent or greater), adequate (between
84.9 percent and 75.0 percent), or inadequate (less than 75.0 percent).
Indicator Ratings and the Overall Medical
Quality Rating
To reach an overall quality rating, our inspectors collaborate and examine all the
inspection findings. We consider the case review and the compliance testing
results for each indicator. After considering all the findings, our inspectors reach
consensus on an overall rating for the institution.
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Appendix B: Case Review Data
Table B–1. CTF Case Review Sample Sets
Sample Set Total
OHU 2
Death Review/Sentinel Events 4
Diabetes 4
Emergency Services – CPR 5
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 4
Intra-system Transfers In 3
Intra-system Transfers Out 3
RN Sick Call 23
Specialty Services 4
58
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Table B–2. CTF Case Review Chronic Care Diagnoses
Diagnosis Total
Anemia 1
Arthritis/Degenerative Joint Disease 10
Asthma 7
COPD 5
COVID-19 8
Cancer 2
Cardiovascular Disease 3
Chronic Kidney Disease 4
Chronic Pain 11
Cirrhosis/End-Stage Liver Disease 2
Coccidioidomycosis 3
Diabetes 11
Gastroesophageal Reflux Disease 14
Hepatitis C 10
Hyperlipidemia 20
Hypertension 24
Mental Health 15
Migraine Headaches 2
Seizure Disorder 2
Sleep Apnea 1
Substance Abuse 8
Thyroid Disease 4
167
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Table B–3. CTF Case Review Events by Program
Diagnosis Total
Diagnostic Services 251
Emergency Care 45
Hospitalization 31
Intra-system Transfers In 8
Intra-system Transfers Out 4
Outpatient Care 360
Specialized Medical Housing 83
Specialty Services 68
850
Table B–4. CTF Case Review Sample Summary
Total
MD Reviews Detailed 22
MD Reviews Focused 2
RN Reviews Detailed 15
RN Reviews Focused 35
Total Reviews 74
Total Unique Cases 58
Overlapping Reviews (MD & RN) 16
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Appendix C. Compliance Sampling Methodology
Correctional Training Facility
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least
Patients one condition per patient—any
risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003–006 Nursing Sick Call 32 Clinic Appointment • Clinic (each clinic tested)
(6 per clinic) List • Appointment date (2–9 months)
• Randomize
MIT 1.007 Returns From 20 OIG Q: 4.005 • See Health Information
Community Management (Medical Records)
Hospital (returns from community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001–003 Radiology 10 Radiology Logs • Appointment date
(90 days–9 months)
• Randomize
• Abnormal
MITs 2.004–006 Laboratory 10 Quest • Appt. date (90 days–9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.007–009 Laboratory STAT 0 Quest • Appt. date (90 days–9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.010–012 Pathology 10 InterQual • Appt. date (90 days–9 months)
• Service (pathology related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 32 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 Ips for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 Ips for each question
MIT 4.003 Hospital Discharge 20 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 Ips selected
MIT 4.004 Scanning Accuracy 24 Documents for any • Any misfiled or mislabeled
tested inmate document identified during
OIG compliance review (24 or
more = No)
MIT 4.005 Returns From 20 CADDIS Off-site • Date (2–8 months)
Community Hospital Admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101–105 Clinical Areas 9 OIG inspector • Identify and inspect all on-site
MITs 5.107–111 on-site review clinical areas.
Transfers
MITs 6.001–003 Intrasystem Transfers 25 SOMS • Arrival date (3–9 months)
• Arrived from (another
departmental facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 0 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 See Access to Care
Medication • At least one condition per
patient—any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of Ips
tested in MIT 7.001
MIT 7.003 Returns From 20 OIG Q: 4.005 • See Health Information
Community Hospital Management (Medical Records)
(returns from community hospital)
MIT 7.004 RC Arrivals— N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2–8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 10 SOMS • Date of transfer (2–8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101–103 Medication Storage Varies OIG inspector • Identify and inspect clinical
Areas by test on-site review & med line areas that store
medications
MITs 7.104–107 Medication Varies OIG inspector • Identify and inspect on-site
Preparation and by test on-site review clinical areas that prepare and
Administration Areas administer medications
MITs 7.108–111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 25 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication
error reports (recent 12 months)
MIT 7.999 Restricted Unit
0
On-site active • KOP rescue inhalers &
KOP Medications medication listing nitroglycerin medications for Ips
housed in restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001–007 Recent Deliveries N/A at this OB Roster • Delivery date (2–12 months)
institution • Most recent deliveries (within
date range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2–12 months)
institution • Earliest arrivals (within date
range)
Preventive Services
MITs 9.001–002 TB Medications 3 Maxor • Dispense date (past 9 months)
• Time period on TB meds
(3 months or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior
Annual Screening to inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior
Vaccinations to inspection)
• Randomize
• Filter out Ips tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior
Screening to inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. Prior
institution to inspection)
• Date of birth (age 52–74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs.
institution Prior to inspection)
• Date of birth (age 24–53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP—any risk level)
• Randomize
• Condition must require
vaccination(s)
MIT 9.009 Valley Fever
0
Cocci transfer • Reports from past 2–8 months
status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001–008 Reception Center N/A at this SOMS • Arrival date (2–8 months)
institution • Arrived from (county jail, return
from parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001–004 Specialized Health 4 CADDIS • Admit date (2–8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of
5 days)
• Rx count
• Randomize
MITs 13.101–102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001–003 High-Priority 15 Specialty Services • Approval date (3–9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C,
HIV, orthotics, gynecology,
consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, and
radiology services
• Randomize
MITs 14.004–006 Medium-Priority 15 Specialty Services • Approval date (3–9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C,
HIV, orthotics, gynecology,
consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, and
radiology services
• Randomize
MITs 14.007–009 Routine-Priority 15 Specialty Services • Approval date (3–9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C,
HIV, orthotics, gynecology,
consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
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therapy, physiatry, podiatry, and
radiology services
• Randomize
MIT 14.010 Specialty Services 20 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3–9 months)
• Randomize
MITs 14.011–012 Denials 20 InterQual • Review date (3–9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events (ASE) events report (2–8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 12 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB 0 LGB meeting • Quarterly meeting minutes
minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
MIT 15.103 Death Reports 10 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 10 On-site • All required performance
Evaluation Packets provider evaluation documents
evaluation files
MIT 15.106 Provider Licenses 12 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site • All staff
Response certification ◦ Providers (ACLS)
Certifications tracking logs ◦ Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.109 Pharmacy and All On-site listing • All DEA registrations
Providers’ Drug of provider DEA
Enforcement Agency registration #s
(DEA) Registrations & pharmacy
registration
document
MIT 15.110
Nursing Staff New All
Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998
Death Review 10
OIG summary log: • Between 35 business days &
Committee deaths 12 months prior
• California Correctional
Health Care Services death
reviews
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California Correctional Health Care Services’
Response
(cid:16)(cid:27)(cid:21)(cid:29)(cid:20)(cid:24)(cid:23)(cid:26)(cid:1)(cid:17)(cid:26)(cid:30)(cid:22)(cid:25)(cid:27)(cid:28)(cid:22)(cid:1)(cid:19)(cid:16)(cid:12)(cid:1)(cid:3)(cid:6)(cid:7)(cid:6)(cid:7)(cid:6)(cid:15)(cid:10)(cid:2)(cid:16)(cid:16)(cid:5)(cid:17)(cid:2)(cid:7)(cid:10)(cid:6)(cid:9)(cid:2)(cid:13)(cid:11)(cid:9)(cid:7)(cid:2)(cid:11)(cid:18)(cid:5)(cid:6)(cid:15)(cid:10)(cid:15)(cid:8)(cid:16)(cid:18)(cid:14)(cid:4)
August 19, 2022
Amarik Singh, Inspector General
Office of the Inspector General
10111 Old Placerville Road, Suite 110
Sacramento, CA 95827
Dear Ms. Singh:
The Office of the Receiver has reviewed the draft Medical Inspection Report for the Correctional
Training Facility (CTF) conducted by the Office of the Inspector General (OIG) from February to
July 2021. California Correctional Health Care Services (CCHCS) acknowledges the OIG findings.
Thank you for preparing the report. Your efforts have advanced our mutual objective of ensuring
transparency and accountability in CCHCS operations. If you have any questions or concerns,
please contact me at (916) 896-6780.
Sincerely,
Robin Hart
Associate Director
Risk Management Branch
California Correctional Health Care Services
cc: Clark Kelso, Receiver
Diana Toche, D.D.S., Undersecretary, Health Care Services, CDCR
Directors, CCHCS
Roscoe Barrow, Chief Counsel, CCHCS Office of Legal Affairs
Jackie Clark, Deputy Director, Institution Operations, CCHCS
DeAnna Gouldy, Deputy Director, Policy and Risk Management Services, CCHCS
Renee Kanan, M.D., Deputy Director, Medical Services, CCHCS
Barbara Barney-Knox, R.N., Deputy Director, Nursing Services, CCHCS
Annette Lambert, Deputy Director, Quality Management, CCHCS
Regional Health Care Executive, Region II, CCHCS
Regional Deputy Medical Executive, Region II, CCHCS
Regional Nursing Executive, Region II, CCHCS
Chief Executive Officer, CTF
Katherine Tebrock, Chief Assistant Inspector General, OIG
Doreen Pagaran, R.N., Nurse Consultant Program Review, OIG
Misty Polasik, Staff Services Manager I, OIG
P.O. Box 588500
Elk Grove, CA 95758
Office of the Inspector General, State of California Inspection Period: February 2021 – July 2021 Report Issued: September 2022
Cycle 6
Medical Inspection Report
for
Correctional Training Facility
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Neil Robertson
Chief Deputy Inspector General
STATE of CALIFORNIA
September 2022
OIG