OIG
Correctional Training Facility Cycle 7 Medical Inspection Report
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Cycle 7, Correctional Training Facility | iii
Contents
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 6
Institution-Specific Metrics 7
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 14
Access to Care 14
Diagnostic Services 21
Emergency Services 25
Health Information Management 31
Health Care Environment 37
Transfers 44
Medication Management 51
Preventive Services 59
Nursing Performance 62
Provider Performance 66
Specialized Medical Housing 74
Specialty Services 80
Administrative Operations 88
Appendix A: Methodology 91
Case Reviews 92
Compliance Testing 95
Indicator Ratings and the Overall Medical Quality Rating 96
Appendix B: Case Review Data 97
Appendix C: Compliance Sampling Methodology 101
California Correctional Health Care Services’ Response 109
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
Cycle 7, Correctional Training Facility | iv
Illustrations
Tables
1. CTF Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. CTF Master Registry Data as of January 2024 7
3. CTF Health Care Staffing Resources as of January 2024 8
4. CTF Results Compared With State HEDIS Scores 10
5. Access to Care 18
6. Other Tests Related to Access to Care 19
7. Diagnostic Services 23
8. Health Information Management 34
9. Other Tests Related to Health Information Management 35
10. Health Care Environment 42
11. Transfers 48
12. Other Tests Related to Transfers 49
13. Medication Management 56
14. Other Tests Related to Medication Management 57
15. Preventive Services 60
16. Specialized Medical Housing 78
17. Specialty Services 85
18. Other Tests Related to Specialty Services 86
19. Administrative Operations 89
A–1. Case Review Definitions 92
B–1. CTF Case Review Sample Sets 97
B–2. CTF Case Review Chronic Care Diagnoses 98
B–3. CTF Case Review Events by Program 99
B–4. CTF Case Review Sample Summary 99
Figures
A–1. Inspection Indicator Review Distribution for CTF 91
A–2. Case Review Testing 94
A–3. Compliance Sampling Methodology 95
Photographs
1. Patient Waiting Area 37
2. Expired Medical Supply Dated August 28, 2023 38
3. Expired Medical Supply Dated August 28, 2023 38
4. Medication Stored With Medical Supply 39
5. Medical Supply Stored in the Same Area as Biohazardous Waste 39
6. Medical Supply Stored in the Same Area as Biohazardous Waste 39
7. Expired Medical Supply Dated March 9, 2022 40
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector General
(the OIG) is responsible for periodically reviewing and reporting on the delivery of the
ongoing medical care provided to incarcerated people1 in the California Department of
Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in Cycle 6,
including clinical case review and compliance testing. Together, these methods assess the
institution’s medical care on both individual and system levels by providing 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. Through these methods,
the OIG evaluates the performance of the institution in providing sustainable, adequate care.
We continue to review institutional care using 15 indicators as in prior cycles.3
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). In addition, our clinicians complete document reviews of individual cases and also
perform on-site inspections, which include interviews with staff. The OIG determines a total
compliance score for each applicable indicator and considers the MIT scores in the overall
conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff 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. At the same
time, our clinicians consider whether institutional medical processes led to identifying and
correcting individual or system errors, and we examine whether the institution’s medical
system mitigated the error. The OIG rates each applicable indicator proficient, adequate, or
inadequate, and considers each rating in the overall conclusion of the institution’s health
care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single overall
institution rating. This change will clarify the distinctions between these differing quality
measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
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.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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As we did during Cycle 6, our office continues 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 7 inspection of Correctional Training Facility, the
institution had been delegated back to the department by the receiver.
We completed our seventh inspection of the institution, and this report presents our
assessment of the health care provided at this institution during the inspection period from
June 2023 to November 2023.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between November 2022 and June 2023, and emergency cardiopulmonary resuscitation
reviews between May 2023 and October 2023.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Summary: Ratings and Scores
We completed the Cycle 7 inspection of Correctional Training Facility (CTF) in May 2024. OIG
inspectors monitored the institution’s delivery of medical care that occurred between June
2023 and November 2023.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at CTF adequate. quality at CTF inadequate.
OIG case review clinicians (a team of physicians and nurse consultants) reviewed 42 cases,
which contained 849 patient-related events. They performed quality control reviews; their
subsequent collective deliberations ensured consistency, accuracy, and thoroughness. Our
OIG clinicians acknowledged institutional structures that catch and resolve mistakes that
may occur throughout the delivery of care. After examining the medical records, our
clinicians completed a follow-up on-site inspection in May 2024 to verify their initial
findings. The OIG physicians rated the quality of care for 20 comprehensive case reviews. Of
these 20 cases, our physicians rated 13 adequate and seven inadequate.
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 413 patient records and 1,132 data points and used the
data to answer 89 policy questions. In addition, we observed CTF’s processes during an on-
site inspection in February 2024.
The OIG then considered the results from both case review and compliance testing, and drew
overall conclusions, which we report in 13 health care indicators.5
5 The indicators for Reception Center and Prenatal and Postpartum Care did not apply to CTF.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. CTF Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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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.6
The OIG found no adverse events at CTF during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 10 of the 13
indicators applicable to CTF. Of these 10 indicators, OIG clinicians rated seven adequate and
three inadequate. The OIG physicians also rated the overall adequacy of care for each of the
20 detailed case reviews they conducted. Of these 20 cases, 13 were adequate and seven
were inadequate. In the 849 events reviewed, we identified 286 deficiencies, 80 of which
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 performed well in completing laboratory and radiology tests and reporting
the test results to the providers.
• Provider appointments often occurred within ordered time frames.
• Staff performed well in medication continuity for patients who transferred into
and out of CTF.
Our clinicians found the following weaknesses at CTF:
• Provider performance needed improvement due to poor clinical assessment and
decision-making, lack of attention to detail, and lapses in following through on
documented plans for patients.
• Nursing and medical leadership often did not conduct clinic reviews for
emergency events and did not always identify opportunities for improvement.
• Nurse-to-provider notifications, timely reassessments, and nursing
interventions during emergency events needed improvement.
6 For a further discussion of an adverse event, see Table A–1.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable to CTF. Of these 10
indicators, our compliance inspectors rated one proficient, two adequate, and seven
inadequate. We solely tested policy compliance in Health Care Environment, Preventive
Services, and Administrative Operations as these indicators do not have a case review
component.
CTF showed a high rate of policy compliance in the following areas:
• Nurses reviewed health care services request forms and conducted face-to-face
encounters within required time frames.
• Providers evaluated patients returning from outside community hospitals
within required time frames. Moreover, providers also timely evaluated newly
arrived patients to CTF.
• CTF nursing staff and providers excellently completed nursing and provider
assessments of patients admitted to the outpatient housing unit (OHU) within
required time frames.
CTF showed a low rate of policy compliance in the following areas:
• Staff frequently did not maintain medication continuity for chronic care
patients, patients discharged from the hospital, patients admitted to the
specialized medical housing unit, and patients who had a temporary layover at
CTF.
• Staff did not perform well in ensuring approved specialty services were
provided within specified time frames.
• Providers often did not communicate results of diagnostic tests timely with
complete letters. Most patient test result notification letters were missing the
date of the diagnostic service, the date of the results, or whether the results
were within normal limits.
• Health care staff did not consistently follow universal hand hygiene precautions
during patient encounters.
• CTF’s medical warehouse and clinics had multiple expired medical supplies.
• Nursing staff did not regularly inspect emergency medical response bags.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Institution-Specific Metrics
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 patients requiring outpatient
health services and assistance with the activities of daily living in its OHU. In addition,
patients departing from or arriving to the institution are screened in the receiving and
release (R&R) clinic. California Correctional Health Care Services (CCHCS) has designated
CTF as a basic care institution. Basic care institutions are located in rural areas, away from
tertiary care centers and specialty care providers whose services are more frequently used
by higher-risk patients.7 These institutions provide limited specialty medical services and
consultations for generally healthy patient populations. As of February 19, 2025, the
department reports on its public tracker that 81 percent of CTF’s incarcerated population is
fully vaccinated for COVID-19 while 65 percent of CTF’s staff is fully vaccinated for COVID-
19.8
In January 2024, the Health Care Services Master Registry showed CTF had a total population
of 4,165. A breakdown of the medical risk level of the CTF population as determined by the
department is set forth in Table 2 below.9
Table 2. CTF Master Registry Data as of January 2024
Medical Risk Level Number of Patients Percentage*
High 1 192 4.6%
High 2 466 11.2%
Medium 1,388 33.3%
Low 2,119 50.9%
Total 4,165 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from
the CCHCS Master Registry dated 1-22-24.
7 Notably, institutions designated as “basic” are generally expected to have a total high risk medical population of
approximately 5%. At nearly 16%, CTF’s high risk population is over three times the expected ratio. However, this
institution is still assigned a medical staffing package consistent with its basic designation. We considered this
disadvantage in reaching our inspection findings.
8 For more information, see the department’s statistics on its website page titled Population COVID‑19 Tracking.
9 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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According to staffing data the OIG obtained from CCHCS, as identified in Table 3 below, CTF
had three vacant executive leadership positions, eight primary care provider vacancies, 5.5
nursing supervisor vacancies, and 179.8 nursing staff vacancies.
Table 3. CTF Health Care Staffing Resources as of January 2024
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 6.0 13.0 41.5 339.1 399.6
Filled by Civil Service 5.0 5.0 36.0 159.3 205.3
Vacant 3.0 8.0 5.5 179.8 196.3
Percentage Filled by Civil Service 83.3% 38.5% 86.7% 47.0% 51.4%
Filled by Telemedicine 0 2.0 0 0 2.0
Percentage Filled by Telemedicine 0 15.4% 0 0 0.5%
Filled by Registry 0 4.0 0 110.0 114.0
Percentage Filled by Registry 0 30.8% 0 0 28.5%
Total Filled Positions 5.0 11.0 36.0 269.3 321.3
Total Percentage Filled 83.3% 84.6% 86.7% 79.4% 80.4%
Appointments in Last 12 Months 0 2.0 0 21.0 23.0
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 3.0 20.0 23.0
Adjusted Total: Filled Positions 5.0 11.0 33.0 249.3 298.3
Adjusted Total: Percentage Filled 83.3% 84.6% 79.5% 73.5% 74.6%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes the classifications of 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 7 medical inspection preinspection questionnaire received on 1-22-24, from California Correctional
Health Care Services.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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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 7. 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 California Medi-Cal and Kaiser Medi-Cal
HEDIS scores to use in conducting our analysis, and we present them here for comparison.
HEDIS Results
We considered CTF’s performance with population-based metrics to assess the macroscopic
view of the institution’s health care delivery. Currently, only two HEDIS measures are
available for review: poor HbA1c control, which measures the percentage of diabetic
patients who have poor blood sugar control, and colorectal cancer screening rates for
patients ages 45 to 75. We list the applicable HEDIS measures in Table 4.
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’s percentage of
patients with poor HbA1c control was significantly lower, indicating very good performance
on this measure.
Immunizations
Statewide comparative data were not available for immunization measures; however, we
include these data for informational purposes. CTF had a 49 percent influenza immunization
rate for adults 18 to 64 years old and a 56 percent influenza immunization rate for adults 65
years of age and older.10 The pneumococcal vaccination rate was 82 percent.11
Cancer Screening
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser Northern
California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—CTF’s colorectal cancer
screening rate of 83 percent was higher than all three Medi-Cal programs.
10 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable result.
11 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines (PCV13, PCV15,
and PCV20), 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 where the patient was currently housed during the inspection period.
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Table 4. CTF Results Compared With State HEDIS Scores
CTF California California
Kaiser Kaiser
Cycle 7 California NorCal SoCal
HEDIS Measure Results * Medi-Cal † Medi-Cal † Medi-Cal †
HbA1c Screening 100% – – –
Poor HbA1c Control (> 9.0%) ‡,§ 5% 36% 31% 22%
HbA1c Control (< 8.0%) ‡ 87% – – –
Blood Pressure Control (< 140/90) ‡ 90% – – –
Eye Examinations 83% – – –
Influenza – Adults (18 – 64) 49% – – –
Influenza – Adults (65 +) 56% – – –
Pneumococcal – Adults (65 +) 82% – – –
Colorectal Cancer Screening 83% 37% 68% 70%
Notes and Sources
* Unless otherwise stated, data were collected in February 2024 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, 2022 – June 30, 2023
(published March 2024); https://www.dhcs.ca.gov/dataandstats/reports/Documents/Medi-Cal-Managed-
Care-Technical-Report-Volume-1.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.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Recommendations
As a result of our assessment of CTF’s performance, we offer the following recommendations
to the department:
Access to Care
• Medical and administrative leadership should analyze the success of the
measures they have taken to address the unavailability of the health care
services request forms (CDCR form 7362) and implement any further remedial
measures if needed.
Diagnostic Services
• The department should develop and implement strategies, such as an electronic
solution, to ensure providers create patient letters that contain all elements
required by CCHCS policy when they endorse test results.
Emergency Services
• Nursing leadership should determine the root cause(s) of challenges that
prevent nurses from performing thorough assessments and reassessments,
notifying the provider of abnormal clinical findings, and providing appropriate
interventions for patients with emergent and urgent conditions. Leadership
should implement remedial measures as appropriate.
• Medical and nursing leadership should determine the root cause(s) of
challenges in completing thorough clinical reviews of urgent and emergent
events in which patients transfer to the community hospital and in identifying
opportunities for improvement. Leadership should implement remedial
measures as appropriate.
Health Information Management
• CTF leadership should develop and implement strategies to ensure staff
properly scan and label documents in the electronic health record system
(EHRS), as required by CCHCS policy.
Health Care Environment
• Medical and nursing leadership should determine the root cause(s) for staff not
following all required universal hand hygiene precautions and should
implement remedial measures as appropriate.
• Executive leadership should determine the root cause(s) for staff not following
equipment and medical supply management protocols and should implement
remedial measures as appropriate.
• Nursing leadership should determine the root cause(s) for staff not ensuring the
emergency medical response bags (EMRBs) are regularly inventoried and sealed
and should implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Medication Management
• Health care leadership should develop and implement measures to ensure staff
timely make available and administer chronic care medications, newly ordered
medications, community hospital discharge medications, and medications for
patients temporarily housed at the institution. Leadership should implement
remedial measures as appropriate.
• Nursing leadership should develop and implement measures to ensure nursing
staff document administering medications, patient refusals, and no-shows in the
electronic health record in accordance with CCHCS’s policies and procedures.
Leadership should implement remedial measures as appropriate.
Preventive Services
• Nursing leadership should develop and implement measures to ensure the
nursing staff monitor patients who are receiving TB medications according to
CCHCS policy.
• Medical leadership should determine the root cause(s) for challenges to timely
providing vaccinations to chronic care patients and should implement remedial
measures as appropriate.
Nursing Performance
• Nursing leadership should ensure nurses assess patients with urgent
complaints the same day and notify the providers when patients’ conditions are
warranted. Leadership should implement remedial measures as appropriate.
Provider Performance
• Medical leadership should analyze the root cause(s) of poor assessments,
emergency care, medical record review, specialty follow-up, documentation,
specialized medical housing care, and chronic condition management and
should implement remedial measures as appropriate.
• Medical leadership should develop strategies to ensure complete and thorough
review of emergency cases and implement remedial measures as appropriate.
Specialized Medical Housing
• Nursing leadership should develop strategies to ensure nurses perform
thorough patient admission assessments and notify providers of any abnormal
changes in patients’ conditions and should implement remedial measures as
appropriate.
Specialty Services
• CTF leadership should determine the root cause(s) of challenges to timely
providing specialty appointments and should implement remedial measures as
appropriate.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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• CTF leadership should ascertain the challenge(s) to the receiving specialty
reports within required time frames and should implement remedial measures
as appropriate.
• Medical leadership should determine the root cause(s) of providers not
following specialists’ recommendations or not clearly documenting the medical
rationale for not following specialist’s recommendations and should implement
necessary remedial measures.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Indicators
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing patients
with timely clinical appointments. Our inspectors reviewed scheduling and appointment
timeliness for newly arrived patients, sick calls, and nurse follow-up appointments. We
examined referrals to primary care providers, provider follow-ups, and specialists.
Furthermore, we evaluated the follow-up appointments for patients who received specialty
care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (81.6%)
Case review found CTF provided good access to care. CTF offered excellent access to clinic
providers and nurses, and good access to providers after hospitalizations and emergency
care. Nurses and providers almost always evaluated transfer-in patients within required time
frames. Providers often timely evaluated and completed initial history and physicals for
specialized medical housing patients. However, specialty services access needed
improvement. After reviewing all aspects of access to care, the OIG rated the case review
component of this indicator adequate.
Compliance testing showed CTF performed satisfactorily in access to care. Staff performed
excellently with nurses’ reviews of patient sick call requests, completing face-to-face nurse
encounters, offering provider follow-up appointments for patients returning from
hospitalizations, and provider appointments for patients who transferred into CTF. Staff also
often completed provider chronic care follow-up appointments and provider appointments
for patients who returned from specialty services. However, CTF scored low for maintaining
patient sick call forms in the housing units. Based on the overall compliance score result, the
OIG rated this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 218 provider, nursing, urgent or emergent care (TTA), specialty, and
hospital events requiring the institution to generate appointments. We identified 14
deficiencies relating to Access to Care, 11 of which were significant.12
Access to Care Providers
Access to clinic providers is an integral part of patient care in health care delivery.
Compliance testing showed chronic care face-to-face follow-up appointments often occurred
timely (MIT 1.001, 80.0%). OIG clinicians found providers usually completed chronic care
12 Access to care deficiencies occurred in cases 2, 11, 12, 18, 21, 22, 24, 41, and 42. Significant occurred in cases 2,
12, 18, 21, 22, 24, and 42. Notably, we considered the number of access deficiencies in light of the significantly larger
high-risk medical population CTF must attend to as compared with most institutions designated “basic.”
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
Cycle 7, Correctional Training Facility | 15
appointments within ordered time frames. We identified three deficiencies, two of which
were significant, as described below:13
• In case 12, the patient with uncontrolled diabetes required an appointment with
a CTF provider for preoperative clearance prior to surgery; however, that CTF
provider appointment did not occur until after the surgery was complete.
• In case 21, the patient with asthma, high cholesterol, and chronic back pain was
not scheduled for a chronic care appointment with a provider for 20 months.
The patient should have been seen more frequently.
Both compliance testing and case review found patients did not always have access to health
care services request forms (CDCR form 7362). This is discussed further in the Clinician On-
Site Inspection section below.
Access to Specialized Medical Housing Providers
CTF provided fair access to specialized medical housing providers. OIG clinicians found
providers usually performed patient intake history and physicals timely; however, we found
the following deficiency:
• In case 2, during a 25-day period, the patient with a history of frequent medical
procedures, hospitalizations, and emergency encounters was not seen by a
primary care provider. The patient should have been assessed more frequently.
Access to Clinic Nurses
CTF performed excellently with access to nurse sick calls and provider-to-nurse referrals.
Compliance testing showed nurses always reviewed medical requests for services the day
they were received (MIT 1.003, 100%) and frequently completed face-to-face appointments
within required time frames (MIT 1.004, 93.3%). OIG clinicians reviewed 54 nursing sick call
requests in 23 cases and identified no deficiencies related to clinic nurse access.
Access to Specialty Services
CTF provided variable access to specialists. Compliance testing revealed an excellent
completion rate of high-priority specialty appointments (MIT 14.001, 93.3%), a very good
completion rate of routine-priority specialty appointments (MIT 14.007, 86.7%), but a poor
completion rate of medium-priority specialty appointments (MIT 14.004, 66.7%) within
ordered time frames. Case review found seven deficiencies in access to specialty services,
five of which were significant.14 These are discussed further in the Specialty Services
indicator.
13 Access to provider deficiencies occurred in cases 11, 12, and 21.
14 Specialty services access deficiencies occurred in cases 1, 12, 18, 22, 41 and 42. Significant deficiencies occurred
in cases 2, 12, 18, 22, and 42.
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Follow-Up After Specialty Services
Compliance testing revealed provider appointments after specialty services usually occurred
within required time frames (MIT 1.008, 76.2%). Case review clinicians found the following
one deficiency, which was significant:
• In case 24, the patient returned from an off-site MRI and was supposed to be
seen 14 days later by a CTF provider; however, that appointment did not occur.15
Follow-Up After Hospitalization
CTF performed outstandingly in completing provider follow-up appointments after
hospitalization (MIT 1.007, 95.8%). Case review found similar results, with only one
deficiency, which was significant:
• In case 21, the patient was hospitalized for seven days for acute respiratory
failure and status asthmaticus.16 The patient was scheduled to see his primary
care provider in five days after hospital discharge; however, that appointment
did not occur for one month.
Follow-Up After Urgent or Emergent Care (TTA)
Providers generally evaluated their patients following a TTA event as medically indicated.
OIG clinicians reviewed 36 TTA events and identified one deficiency, which was significant:
• In case 24, TTA staff evaluated the patient for a red, swollen, and painful arm,
indicative of an infection. The provider requested a follow-up appointment
within five days; however, this appointment did not occur.
Follow-Up After Transferring Into CTF
CTF performed very well with access to care for patients who had recently transferred into
the institution. Compliance testing showed very good access to intake appointments for
newly arrived patients (MIT 1.002, 92.0%). Case reviewers did not find any deficiencies.
Clinician On-Site Inspection
OIG clinicians met and discussed care access with CTF’s executive leadership, medical and
nursing leadership, the correctional health services administrator (CHSA), and schedulers.
CTF had seven outpatient clinics, an OHU, a TTA unit, and on-site specialty services requiring
appointment scheduling. The registered nurse (RN) clinics were scheduled with a concerted
effort between RN medical services triage and the schedulers. Factors affecting provider
appointment availability included a loss of three physicians and restructuring of the
outpatient clinics, which increased the patient panels for the remaining physicians. To reduce
provider appointment backlog, the providers worked extended hours, and the chief
15 An MRI is a magnetic resonance imaging scan. The scan creates detailed images of the organs and tissues to
detect diseases and abnormalities.
16 Status asthmaticus is an acute, severe asthma exacerbation that does not improve with standard treatments. This
condition may lead to respiratory failure and require hospitalization.
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Cycle 7, Correctional Training Facility | 17
physician and surgeon (CP&S) and the chief medical executive (CME) evaluated patients in
addition to their administrative duties.
At the on-site inspection, OIG clinicians identified few to no health care services request
forms available for patient use on the yards. Availability of these forms is critical to patients
having access to medical care. Without these forms, the patient’s only alternative to access
medical care is to tell custody or medical staff about their symptoms or wait until their
symptoms worsen, then go “man down” to initiate an emergency event.17 Custody on several
yards informed OIG clinicians that regardless of how many forms they put out, the patients
hoard the forms, reducing the supply of the forms very quickly. In some yards, when asked
how to replenish the forms, medical and custody staff either didn’t know or gave differing
responses, indicating the inmates could obtain them from the clinic custody or yard nurses.
However, in our observations, clinic custody could not always readily locate the forms, and
the patients had limited nursing access on the yards. The OIG’s compliance nurses made
similar observations at their on-site inspection.
The CHSA is responsible for managing the health care services request forms. Both the CHSA
and her staff confirmed they are aware of the form availability problem and reported they
are establishing more defined protocols for replenishing supplies as well as increasing
locations where forms can be obtained. In addition, the CHSA clarified staff must complete a
warehouse request form to request new health care services request forms, and they are
educating custody and medical staff on how to obtain, use, and process these forms.
Compliance On-Site Inspection
Only one of six housing units randomly tested at the time of inspection had access to health
care services request forms (MIT 1.101, 16.7%). In four housing units, custody officers did
not have a system in place for restocking the forms. The custody officers reported reliance on
medical staff to replenish the forms in the housing units. The remaining housing unit did not
have a health care services request form available at the time of our inspection.
17 Man down is term to signify when a patient is incapacitated and needs emergency help.
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Compliance Score Results
Table 5. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent chronic
care visit within the health care guideline’s maximum allowable interval or 20 5 0 80.0%
within the ordered time frame, whichever is shorter? (1.001)
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 23 2 0 92.0%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
30 0 0 100%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
28 2 0 93.3%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
4 1 25 80.0%
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 frame 1 0 29 100%
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
23 1 1 95.8%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
16 5 24 76.2%
occur within required time frames? (1.008) *
Clinical appointments: Do patients have a standardized process to obtain
1 5 6 16.7%
and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 81.6%
* 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 6. 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 days (prior N/A N/A N/A N/A
to 07/2022) or five working days (effective 07/2022)? (12.004)
Was a written history and physical examination completed within the
10 0 0 100%
required time frame? (13.002)
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 14 1 0 93.3%
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 9 4 2 69.2%
provider? (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 Request 10 5 0 66.7%
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 provider? 5 1 9 83.3%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 13 2 0 86.7%
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 5 1 9 83.3%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Correctional Training Facility | 20
Recommendations
• Medical and administrative leadership should analyze the success of the
measures they have taken to address the unavailability of the health care
services request forms (CDCR form 7362) and implement any further remedial
measures if needed.
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Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s performance in timely completing
radiology, laboratory, and pathology tests. Our inspectors determined whether the institution
properly retrieved the resultant reports and whether providers reviewed the results
correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (66.7%)
Case review found CTF performed well in diagnostic services. Staff completed radiology and
laboratory tests within specified time frames and obtained reports timely. Providers usually
endorsed related reports as required and sent patient results notification letters; however,
those letters often did not contain all components required by CCHCS policy. Factoring in all
aspects of care, the OIG rated the case review component of this indicator adequate.
Compliance testing showed mixed performance for CTF in diagnostic services. Staff
performed acceptably to excellently in providing radiology services and endorsing diagnostic
results. Staff also frequently completed laboratory services and retrieved pathology reports.
However, providers performed poorly in generating patient notification letters with all
required key elements. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 119 diagnostic events and identified 62 deficiencies, two of which were
significant. All 62 deficiencies related to health information management.18
Test Completion
Compliance testing showed CTF always completed radiology services (MIT 2.001, 100%) and
often completed laboratory services (MIT 2.004, 80.0%) within required time frames. Of the
199 diagnostic events reviewed by OIG clinicians, CTF always completed diagnostic
laboratory and on-site radiology studies within ordered time frames, and almost always
retrieved and endorsed results timely.
Neither case review nor compliance testing had any STAT laboratory tests in their samples to
review (MIT 2.007, NA).
Health Information Management
CTF staff retrieved diagnostic results promptly and sent them to providers for review.
Compliance testing showed providers always timely endorsed radiology reports (MIT 2.002,
18 Deficiencies occurred in cases1, 2, 9, 11–17, 20–25, 41, and 42. Significant deficiencies occurred in cases 9 and 12.
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100%) and often timely endorsed laboratory reports (MIT 2.005, 90.0%). This is consistent
with case review findings.
In both compliance testing and case review, providers performed poorly in communicating
laboratory and radiology test results to their patients. Compliance testing showed providers
sometimes communicated radiology results (MIT 2.003, 50.0%) and sporadically
communicated laboratory test results (MIT 2.006, 20.0%) with complete test results
notification letters to patients within required time frames. Case review found 54 of the 62
health information management (HIM) diagnostic deficiencies related to patient notification
letters missing required elements.
Compliance testing showed staff performance was sufficient in both the retrieval of final
pathology reports within the required time frames (MIT 2.010, 80.0%) and provider review
and endorsement of the pathology results (MIT 2.011, 80.0%); however, staff never
communicated the results of the pathology reports with complete test results notification
letters to patients within required time frames (MIT 2.012, zero). In the three pathology
related events, case review identified one minor deficiency.
Clinician On-Site Inspection
We met with CTF’s diagnostic and health information management leadership. According to
leadership, the CTF radiology area was undergoing remodeling during the review period.
CTF had a portable x-ray unit available; however, the unit could not accommodate lower
extremities or patients over 250 pounds. Consequently, patients received most x-rays either
at Salinas Valley State Prison (SVSP), the institution adjacent to CTF, or at the local hospital.
Leadership also stated, in addition to requiring patient transport out of the institution for
imaging studies, sharing x-ray facilities with SVSP was problematic because SVSP is a Level 4
institution, and health care staff needed to consider custody concerns. Furthermore, CTF’s
radiology technician had transferred to SVSP due to CTF’s lack of equipment. This resulted in
both institutions sharing one radiology technician until new technicians could be hired.
Radiology technicians from other institutions staffed weekend imaging clinics, which
reduced the radiology backlog.
CTF leadership stated hiring radiology and laboratory staff was a challenge. Leadership
reported difficulty in recruiting and retaining staff due to the high cost of living locally and
better pay at local community hospitals.
As with some other CCHCS institutions, a contracted vendor performed on-site specialty
imaging, such as CTs and MRIs.19 This vendor uploaded the imaging results directly into
EHRS, which staff then forwarded to the providers for review and endorsement. CTF staff
stated the service was very efficient in reading and sending the imaging reports back to CTF.
19 A CT is a computed, or computerized, tomography scan. This scan creates detailed images of the organs and
tissues to detect diseases and abnormalities.
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Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
10 0 0 100%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
5 5 0 50.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
8 2 0 80.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
2 8 0 20.0%
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
N/A N/A N/A N/A
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frames? (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 within the
8 2 0 80.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
8 2 0 80.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 9 1 0
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 66.7%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• The department should develop and implement strategies, such as an electronic
solution, to ensure providers create patient letters that contain all elements
required by CCHCS policy when they endorse test results.
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Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed the institution’s emergency medical response system by examining the
timeliness and appropriateness of clinical decisions made during medical emergencies. Our
evaluation included examining the emergency medical response, cardiopulmonary
resuscitation (CPR) quality, triage and treatment area (TTA) care, provider performance, and
nursing performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services.
The OIG assessed the institution’s emergency services solely through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
OIG clinicians found CTF needed improvement in emergency services. In comparison with
Cycle 6, we reviewed more events but had a similar number of deficiencies. However, our
clinicians found CTF continued to have challenges with nursing assessments and
interventions during emergency events. Moreover, medical leadership often did not conduct
clinical reviews, or when clinical reviews were conducted, they did not identify opportunities
for improvement. Although provider performance with emergency events was sufficient,
factoring all the information, the OIG rated this indicator as inadequate.
Case Review Results
We reviewed 61 urgent or emergent events and found 48 deficiencies. Of these 48
deficiencies, 15 were significant.20
Emergency Medical Response
CTF staff mostly timely responded to emergency events throughout the institution, activated
emergency medical services (EMS), and notified TTA staff.
Our clinicians reviewed 56 emergency events, which required a response from a medical first
responder. We identified two significant deficiencies related to emergency response delays.21
The following are examples:
• In case 1, the TTA RN responded to a medical alarm for the patient with
complaints of severe abdominal pain. However, the RN first responder arrived at
the patient 12 minutes after alarm activation, which was four minutes beyond
the required time frame established in the CCHCS policy.
20 Deficiencies occurred in cases 1–4, 7, 8, 13, 15, 18–21, 24, and 42. Significant deficiencies occurred in cases
1–4, 7, 8, 13, and 21.
21 First Medical Responder deficiencies occurred in cases 1, 2, 7, 19, and 21. Significant deficiencies occurred in
cases 1 and 7.
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• In case 7, a medical alarm was activated for the patient found hanging in his cell.
Staff did not call 9-1-1 for nine minutes.
Cardiopulmonary Resuscitation Quality
Our clinicians reviewed six cases in which cardiopulmonary resuscitation (CPR) was
initiated.22 Custody and medical staff started CPR promptly, administered naloxone, and
activated the 9-1-1 system from the scene.23 However, our clinicians identified two
deficiencies in which nurses did not appropriately assess the patients after they had a
spontaneous return of circulation. The following are examples:
• In case 3, custody staff initiated CPR on the patient who was found
unresponsive. However, after the patient regained consciousness, the nurses did
not assess the patient’s respiratory rate, reassess the low oxygenation
saturation rate, or reassess the patient’s mental status.
• In case 4, staff initiated CPR on the patient who was found unresponsive in the
OHU. The patient regained consciousness after the third dose of naloxone was
administered. However, the nurses did not assess the patient’s respiratory rate
or oxygenation saturation rate to ensure the patient was sufficiently breathing.
In addition, the nurses did not continue to monitor the patient’s vital signs and
mental status every five minutes.
Provider Performance
CTF providers’ performance was fair in urgent and emergent situations and in after-hours
care. In the 61 emergency events we reviewed, the providers generally performed adequate
assessments, developed appropriate treatment plans, and ensured patient transport orders
were medically appropriate. However, we identified seven provider deficiencies, three of
which were significant.24 The following is an example:
• In case 13, the nurse contacted the on-call provider about a patient who fell on
his left shoulder and was experiencing severe pain with reduced range of
motion. In addition, the nurse described the shoulder as a “bone popped out on
top of the shoulder.” Although the provider did not examine the patient, the
provider documented the shoulder had a slight bulge but was otherwise normal.
The provider diagnosed the patient with a shoulder strain, ordered pain
medication, and sent the patient to the housing unit for a nurse follow-up in two
days. A few hours later, due to severe pain, the patient was sent to the hospital
and diagnosed with a shoulder dislocation. The provider should have
considered this diagnosis and offered appropriate treatment when first
contacted by the nurse.
22 CPR events occurred in cases 3–7 and 9.
23 Naloxone is a medication used for the emergency treatment of known or suspected opioid overdose.
24 Provider related deficiencies occurred in cases 2, 13, 20, 21, 24, and 42. Three significant deficiencies occurred in
cases 2 and 13.
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Nursing Performance
Our clinicians identified opportunities for improvement with nursing assessments for
patients evaluated in the TTA. We identified a pattern of incomplete nursing assessments and
found nurses did not always recheck vital signs, assess pain levels, or contact the provider for
further plan of care. The following are examples:
• In case 1, the TTA RN evaluated the patient for abdominal pain, nausea, and
vomiting. The nurse administered medication to treat nausea and vomiting;
however, the nurse did not reassess the patient for improvement in nausea and
did not reassess the patient’s abdominal pain for improvement. Similar
deficiencies occurred in cases 2, 4, 8, and 21.
• In case 8, the TTA RN evaluated the patient with complaints of severe low back
pain and lower extremity numbness. The patient’s blood pressure and pulse
were both elevated. However, the TTA nurse did not reassess the patient’s vital
signs or pain level for two hours and 40 minutes while in TTA prior to the
patient transferring to a higher level of care.
• Also in case 8, the TTA RN evaluated the patient with complaints of low back
pain and an episode of shortness of breath, dizziness, and constipation. The TTA
nurse did not assess the duration of the patient’s symptoms or perform a
reassessment when the patient reported additional symptoms, nor did the
nurse reassess the patient’s vital signs. Upon assuming care, the RN on the next
shift did not perform an independent assessment to include pain level before
medication was administered. Furthermore, neither RN notified the provider of
the patient’s change in condition after the initial notification to the provider.
• In case 21, the TTA RN evaluated the patient for complaints of shortness of
breath and chest tightness. The nurse administered two nebulizer breathing
treatments and one dose of prednisone per CCHCS nursing protocol.25 Despite
these treatments, the patient continued to have wheezing. However, the nurse
did not notify the provider immediately of the patient’s symptoms per CCHCS
nursing protocol or prior to the patient being discharged back to the housing
unit. In addition, the nurse did not obtain expiratory peak flow before and after
treatments, assess lung sounds, or reassess chest pain severity and shortness of
breath.
We also identified six deficiencies related to nursing interventions, two of which were
significant.26 The following is an example of a significant deficiency:
• In case 2, the OHU patient had an elevated heart rate and severe abdominal pain.
A licensed vocational nurse (LVN) consulted a TTA RN, and the patient was
transported by wheelchair to the TTA. However, neither the LVN nor the RN
accompanied the patient to the TTA; instead, the patient was escorted only by
custody staff. Upon arrival to the TTA, the patient had shortness of breath,
labored breathing, and lower extremity swelling. Despite the patient’s
25 Prednisone is a steroid medication used to decrease inflammation or swelling.
26 Nursing intervention deficiencies occurred in cases 2, 8, 15, 18, 21, and 24. Significant deficiencies occurred in
cases 2, 8, and 21.
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presentation, the nurse did not consult a provider until 39 minutes after the
patient’s arrival to the TTA.
Nursing Documentation
CTF nurses intermittently performed thorough documentation for emergency events. We
identified eight deficiencies related to nursing documentation.27 The following is an example:
• In case 1, the nurse assessed the patient with complaints of abdominal pain. The
nurse documented the patient’s abdomen was soft and bowel sounds were
present. However, the nurse did not document if the patient’s abdomen was
tender or nontender upon palpation.
Emergency Medical Response Review Committee
Compliance testing showed the Emergency Medical Response Review Committee (EMRRC)
often either did not complete the required checklists or did not timely complete reviews
(MIT 15.003, 25.0%). Our clinicians reviewed 25 emergency events in which patients
transferred to a higher level of care. Although, the supervising registered nurses (SRNs)
frequently completed the emergency response checklist form, we found 17 deficiencies in
which either the chief nurse executive (CNE) and the CME did not conduct a clinical review
or, when clinical reviews were conducted, the CNE and CME did not identify opportunities
for improvement.28 The following are examples:
• In case 1, the SRN conducted a clinical review on the patient who was
transferred to a community hospital emergency room for further evaluation of
epigastric pain. However, this clinical review omitted that the TTA nurse did not
reassess complete vital signs for the one and a half hours before the patient
transferred to a higher level of care. Neither the CME nor the CNE performed
clinical reviews. As a result, no training issues were identified, despite the
above-noted lapse in reassessment.
• In case 8, the SRN and the CME completed the clinical review for the patient
who was transferred to a higher level of care for complaints of severe pain and
numbness to the lower extremities. However, the CNE did not conduct a clinical
review.
• In case 21, the SRN completed a clinical review for the patient who was
transferred to a higher level of care for difficulty breathing and throbbing head
pain. However, neither the CNE nor the CME performed clinical reviews.
Clinician On-Site Inspection
OIG clinicians had the opportunity to interview TTA RNs and the TTA nursing supervisor. The
RNs shared they used the gurney to respond to emergency events in the central, east, and
west wings, and would use their one emergency response vehicle when responding to the
North A and North B yards. If additional help was needed, CTF fire crew would assist with
transport, as a backup. The nurses shared they were notified by radio for emergency alarms
27 Nursing documentation deficiencies occurred in cases 1, 3, 8, and 15.
28 EMRRC deficiencies occurred in cases, 1–4, 7, 8, 19, 21, and 24.
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and the clinic RNs and LVNs were the first responders. TTA RNs would also respond when
requested.
CTF had three TTA examination rooms. TTA staff reserved one of the rooms for observation
and used other two rooms to provide emergency care and assess patients. The TTA was
staffed with two RNs for each of three shifts. The TTA nurse indicated they were responsible
for assessing each patient who returns from a community hospital or a specialist
appointment. Furthermore, on the weekends and holidays, the TTA nurses were tasked with
issuing medication for paroling patients.
During the on-site inspection, our clinicians observed a TTA huddle. The huddle participants
included the utilization management RN, off-site specialty nurses, and specialized medical
housing nurses. The TTA nurses discussed patients who had been evaluated in the TTA. The
participants also discussed patients who were currently admitted to a community hospital
and reviewed the off-site specialty appointments for that day.
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Recommendations
• Nursing leadership should determine the root cause(s) of challenges that
prevent nurses from performing thorough assessments and reassessments,
notifying the provider of abnormal clinical findings, and providing appropriate
interventions for patients with emergent and urgent conditions. Leadership
should implement remedial measures as appropriate.
• Medical and nursing leadership should determine the root cause(s) of
challenges in completing thorough clinical reviews of urgent and emergent
events in which patients transfer to the community hospital and in identifying
opportunities for improvement. Leadership should implement remedial
measures as appropriate.
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
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Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link in
high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (72.7%)
Case review found CTF performed sufficiently with managing health information. Staff timely
retrieved, scanned, and endorsed most hospital discharge records and emergency room
reports; however, some records were not complete. In addition, retrieval of specialty
documents needed improvement. Providers sent patient results notification letters within
required time frames, but many notification letters did not contain all CCHCS required
components. Overall, the OIG rated the case review component of this indicator adequate.
Compliance testing showed mixed performance in this indicator. Staff always timely scanned
patient sick call requests, along with almost always timely retrieving and scanning hospital
records. However, staff performed poorly in properly scanning and labeling medical records
into the correct patient files. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 849 events and identified 82 deficiencies related to health information
management (HIM), of which nine were significant. Six of the nine significant deficiencies
related to delayed or missing specialty services documentation.29
Hospital Discharge Reports
CTF staff timely retrieved community hospital discharge records and scanned them into the
EHRS within required time frames (MIT 4.003, 90.0%). OIG clinicians reviewed 21 off-site
emergency department and hospital encounters and identified three deficiencies, only one of
which was a significant deficiency. All three deficiencies related to missing or incomplete
hospital records.30
29 Deficiencies occurred in cases 1, 2, 9, 11–18, 20–25, 41, and 42. Significant deficiencies occurred in cases 1, 2, 9,
12, and 22–25. Significant specialty services deficiencies occurred in cases 1, 2, and 22–25.
30 Deficiencies occurred in cases 2 and 24.
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Specialty Reports
CTF’s performance was mixed in managing specialty reports. Compliance testing showed
CTF frequently scanned the specialty reports timely (MIT 4.002, 93.3%). However, CTF
struggled in the retrieval and timely review of high-priority (MIT 14.002, 60.0%), medium-
priority (MIT 14.005, 66.7%), and routine-priority (MIT 14.008, 60.0%) specialty reports.
Case review also identified deficiencies in managing specialty consultation reports. Of 72
specialty events, case review identified 18 deficiencies related to health information
management, six of which were significant.31 Three of the significant deficiencies related to
severely delayed or missing specialty consultation reports. We discuss these findings in the
Specialty Services indicator.
Diagnostic Reports
CTF’s performance in managing diagnostic reports was mixed. In both compliance testing
and case review, providers endorsed diagnostic studies timely and often communicated the
results to patients with notification letters; however, the notification letters frequently lacked
all CCHCS required components. Staff usually retrieved pathology results timely, but
providers never communicated the pathology results with complete notification letters
within required time frames. Neither case review nor compliance testing had any STAT
laboratory tests in their samples to review. Please refer to the Diagnostic Services indicator
for further details.
Urgent and Emergent Records
OIG clinicians reviewed 61 emergency care events and found providers and nurses
documented these events well, including on-call telephone encounters. Refer to the
Emergency Services indicator for additional information.
Scanning Performance
CTF performed variably in scanning medical documents. Compliance testing revealed staff
did not properly scan, label, or include documents to the correct patient files (MIT 4.004,
zero). The OIG clinicians identified six deficiencies related to mislabeled, misfiled, or
duplicate medical documents, but only one was clinically significant as described below:
• In case 9, staff incorrectly scanned an abnormal electrocardiogram (EKG) result
into the wrong patient’s chart.32
Clinician On-Site Inspection
We discussed health information management processes with CTF’s medical leadership, HIM
supervisors, utilization management (UM) supervisors, office technicians, ancillary staff,
diagnostic staff, nurses, and providers. HIM had new leadership and staff who had
transferred from SVSP’s HIM department.
31 Deficiencies in specialty services documents occurred in cases 1, 2, 12, 17, 18, and 22–25. Significant deficiencies
occurred in cases 1, 2, and 22–25.
32 HIM scanning deficiencies occurred in cases 9, 13, 18, 22, 24, and 25.
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In addition to a new management team learning and updating the HIM process, the HIM
supervisors reported staffing shortages during the review period. Staff worked overtime to
ensure patient documentation was available for medical staff review. Leadership stated most
of the HIM positions are entry level, and they frequently lose these staff to promoting levels
of office technician, health records technicians (HRT), or analyst positions.
Leadership stated another challenge was HIM’s staff location in the institution. Staff work in
older buildings, which frequently have electrical outages, preventing the staff from
completing their work timely. At the time of our inspection, leadership was considering
acquiring laptop computer solutions, which would still work during the intermittent power
outages.
HIM staff did not have access to any of the outside electronic medical records systems where
CTF patients were treated. However, the UM supervisor stated UM staff did have access. UM
staff access the local hospital records system, which expedites receipt of hospital discharge
and emergency room records. Once the UM staff obtain those records, HIM staff scan them
into EHRS and forward them to the providers for review and endorsement. HIM leadership
acknowledged sometimes staff scanned incomplete records or scanned the records
incorrectly. To remedy this, HIM leadership discussed their plan to train staff to ensure
hospital and emergency room records are complete and staff scan all documents correctly.
During their case reviews, OIG clinicians identified problems with receiving off-site specialty
reports. CTF leadership explained an HRT is assigned to obtain and scan off-site specialty
reports, then forward them to the providers for endorsement. HIM supervisors reported
implementing a daily log to ensure staff timely obtain records. When the specialist directly
enters on-site reports into EHRS, HIM supervisors stated the HRT ensured the reports were
entered timely and forwarded them to the providers for review and endorsement.
Regarding the patient results notification letters with missing components, HIM supervisors
stated medical leadership was responsible for training the providers to timely and correctly
complete patient notification letters. The CP&S demonstrated a new enhancement to the
existing letter generation program that the CP&S believed would help.
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Compliance Score Results
Table 8. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s electronic
20 0 10 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
28 2 15 93.3%
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 hospital discharge? 18 2 5 90.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
0 24 0 0
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 and did a provider 20 5 0 80.0%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 72.7%
Source: The Office of the Inspector General medical inspection results.
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Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
10 0 0 100%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
8 2 0 80.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
8 2 0 80.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 9 1 0
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 9 6 0 60.0%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 10 5 0 66.7%
frame? (14.005)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 9 6 0 60.0%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Correctional Training Facility | 36
Recommendations
• CTF leadership should develop and implement strategies to ensure staff
properly scan and label documents in EHRS, as required by CCHCS policy.
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Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection control,
sanitation procedures, medical supplies, equipment management, and examination rooms.
Inspectors also tested clinics’ performance in maintaining auditory and visual privacy for
clinical encounters. Compliance inspectors asked the institution’s health care administrators
to comment on their institution’s infrastructure and its ability to support health care
operations. The OIG rated this indicator solely on the compliance score. Case review does not
rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining the
institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (52.6%)
Overall, CTF performed poorly with respect to its health care environment. We found medical
supply storage areas contained expired medical supplies, contained compromised sterile
medical supply packaging, or stored medical supplies directly on the floor; several
examination room areas were unsanitary; emergency medical response bag (EMRB) logs
were missing staff verification or missing documentation of inventory checks when seal tags
were changed; and staff did not properly wash their hands throughout patient encounters.
Based on the overall compliance score result, the OIG rated this indicator inadequate.
Compliance Testing Results
Patient Waiting Areas
We inspected only indoor waiting areas,
as CTF had no outdoor waiting areas.
Patients had enough seating capacity
while waiting for their appointments (see
Photo 1). These waiting areas had
temperature control, running water, and
toilets. During our inspection, we did not
observe overcrowding in any of the
clinics’ patient waiting areas.
Clinic Environment
All clinic environments were sufficiently
conducive for medical care; they provided
reasonable auditory privacy, appropriate Photo 1. Patient waiting area (photographed on 2-7-24).
waiting areas, wheelchair accessibility, and
nonexamination room workspace (MIT 5.109, 100%).
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Eight of the 10 clinics we observed contained appropriate space, configuration, supplies, and
equipment to allow clinicians to provide proper medical services (MIT 5.110, 80.0%). In two
clinics, the examination room had unsecured confidential patient medical records.
Clinic Supplies
Only one of the 10 clinics followed adequate medical supply storage and management
protocols (MIT 5.107, 10.0%). We found one or more of the following deficiencies in nine
clinics: staff members’ food stored with medical supplies; expired medical supplies (see
Photo 2, below left); unorganized, unidentified, or inaccurately labeled medical supplies;
cleaning materials (see Photo 3, below right) or medications stored with medical supplies
(see Photo 4, next page); medical supplies stored in the designated biohazard waste location
(see Photos 5 and 6, next page); and medical supplies stored directly on the floor.
Photo 2. Expired medical supply dated August 28, 2023
(photographed on 2-6-24).
Photo 3. Cleaning materials stored with medical
supplies (photographed on 2-7-24).
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Photo 4. Medication stored with medical
supplies (photographed on 2-7-24).
Photo 5. Medical supplies stored in the same area as biohazardous waste
(photographed on 2-6-24).
Photo 6. Medical supplies stored in the same area as
biohazardous waste (photographed on 2-6-24).
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Five of the 10 clinics met requirements for essential core medical equipment and supplies
(MIT 5.108, 50.0%). In the remaining five clinics, we found one or more of the following
deficiencies: examination tables missing disposable papers; a nonfunctional
ophthalmoscope; and either inaccurate or incomplete daily glucometer quality control logs.
We examined EMRBs to determine if they contained all essential items. We checked whether
staff inspected the bags daily and inventoried them monthly. Three of the eight applicable
EMRBs passed our tests (MIT 5.111, 37.5%). With the remaining five EMRBs, we found one
or more of the following deficiencies: staff failed to ensure the EMRB compartments were
sealed and intact; staff had not inventoried the EMRBs when seal tags were replaced; and an
EMRB contained a medical item with compromised packaging. In addition, the treatment cart
in the TTA did not meet the minimum inventory level at the time of inspection.
Medical Supply Management
None of the medical supply storage
areas located outside the medical
clinics contained adequately stored
medical supplies (MIT 5.106, zero). We
found expired medical supplies stored
in the medical warehouse (see Photo
7).
According to the CEO, the institution
did not have any concerns about the
medical supply process. Health care
managers and medical warehouse
managers expressed no concerns
about the medical supply chain or
their communication process.
Infection Control and Sanitation
Staff appropriately cleaned, sanitized,
and disinfected two of eight applicable
clinics (MIT 5.101, 25.0%). In six
clinics, we found one or more of the
following deficiencies: staff did not
maintain cleaning logs; staff did not
empty biohazard waste after each
clinic day; the floor under an
examination room sink was
unsanitary; and an examination room
Photo 7. Expired medical supply dated March 9, 2022
drawer was unsanitary.
(photographed on 2-7-24).
Staff in seven of nine applicable clinics
properly sterilized or disinfected medical equipment (MIT 5.102, 77.8%). In two clinics, we
found one or more of the following deficiencies: previously sterilized medical equipment had
compromised packaging; clinical staff did not describe the appropriate sterilization cleaning
process; recently sterilized medical equipment packaging did not change color to indicate
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Cycle 7, Correctional Training Facility | 41
appropriate sterilization; and staff did not date stamp and initial the packaging of sterilized
medical equipment.
We found operational sinks and hand hygiene supplies in seven of 10 clinics (MIT 5.103,
70.0%). The patient restrooms in three clinics either lacked antiseptic soap or disposable
hand towels.
We observed patient encounters in seven clinics. In five clinics, clinicians did not wash their
hands before or after examining their patients (MIT 5.104, 28.6%).
Health care staff in all clinics followed proper protocols to mitigate exposure to bloodborne
pathogens and contaminated waste (MIT 5.105, 100%).
Physical Infrastructure
CTF’s health care management and plant operations manager reported all infrastructure in
clinical areas was in good working order and did not hinder health care services.
At the time of our medical inspection, the institution reported two Health Care Facility
Improvement Program projects. The projects were renovating the Specialty Services Clinic
and the Restricted Housing Unit’s Medication Distribution Room. Both projects started in
March 2021. The institution estimated the projects would be completed by summer 2023
and the first quarter of 2024, respectively. The institution reported the activation of the
Specialty Services Clinic had been delayed pending delivery of necessary furniture. However,
they did not expect the delay to hinder the institution’s ability to deliver specialty services to
their patients (MIT 5.999).
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Compliance Score Results
Table 10. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately disinfected,
2 6 2 25.0%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 7 2 1 77.8%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
7 3 0 70.0%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
2 5 3 28.6%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
10 0 0 100%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 0 1 0 0
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
1 9 0 10.0%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
5 5 0 50.0%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
8 0 2 100%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
8 2 0 80.0%
providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency crash
carts inspected and inventoried within required time frames, and do they 3 5 2 37.5%
contain essential items? (5.111)
Does the institution’s health care management believe that all clinical areas
This is a nonscored test. Please see the
have physical plant infrastructures that are sufficient to provide adequate
indicator for discussion of this test.
health care services? (5.999)
Overall percentage (MIT 5): 52.6%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical and nursing leadership should determine the root cause(s) for staff not
following all required universal hand hygiene precautions and should
implement remedial measures as appropriate.
• Executive leadership should determine the root cause(s) for staff not following
equipment and medical supply management protocols and should implement
remedial measures as appropriate.
• Nursing leadership should determine the root cause(s) for staff not ensuring the
emergency medical response bags (EMRBs) are regularly inventoried and sealed
and should implement remedial measures as appropriate.
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Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions. For
newly arrived patients, our inspectors assessed the quality of health care screenings and the
continuity of provider appointments, specialist referrals, diagnostic tests, and medications.
For patients who transferred out of the institution, inspectors checked whether staff
reviewed patient medical records and determined the patient’s need for medical holds. They
also assessed whether staff transferred patients with their medical equipment and gave
correct medications before patients left. In addition, our inspectors evaluated the
performance of staff in communicating vital health transfer information, such as preexisting
health conditions, pending appointments, tests, and specialty referrals; and inspectors
confirmed whether staff sent complete medication transfer packages to receiving
institutions. For patients who returned from off-site hospitals or emergency rooms,
inspectors reviewed whether staff appropriately implemented recommended treatment
plans, administered necessary medications, and scheduled appropriate follow-up
appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (87.0%)
Case review found CTF performed well in the transfer process. The receiving and release
(R&R) nurses mostly completed health care screenings appropriately and performed
excellently in maintaining medication continuity for patients who transferred into and out of
the institution. Compared with Cycle 6, nursing improved in completing appropriate nursing
assessments for hospital returns and in scheduling nurse and provider appointments timely.
Factoring all the information, the OIG rated the case review component of this indicator
adequate.
Compared with Cycle 6, CTF’s overall compliance performance greatly improved for this
indicator. CTF still needed to improve in completing initial health screening forms. However,
the institution performed perfectly in completing the assessment and disposition section of
the screening process and in ensuring medication continuity for newly transferred patients.
Based on the overall compliance score result, the OIG rated this indicator proficient.
Case Review and Compliance Testing Results
We reviewed 40 events in 19 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, three
of which were significant.33
33 Deficiencies occurred in cases 1, 2, 19–22, 24, 26, 27, 31, 41, and 42. Significant deficiencies occurred in cases 20,
24, and 42.
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Transfers In
Our clinicians reviewed 10 events in which patients transferred into the institution from
other institutions. We identified only two deficiencies related to incomplete nursing
assessments, neither of which was significant.34
Our clinicians found the R&R nurses mostly completed the initial health screening form
thoroughly and did very well with scheduling nurse and provider appointments timely.
Compliance testing showed R7R nurses needed to improve in completing the screening form
timely and providing an explanation for questions answered “yes” on the form (MIT 6.001,
48.0%). However, compliance testing also revealed nurses performed excellently in
completing the assessment and disposition section of the form (MIT 6.002, 100%).
Compliance testing showed CTF performed excellently with maintaining medication
continuity for patients who newly transferred into the institution (MIT 6.003, 100%).
Similarly, patients who transferred within the institution almost always received their
medications without any interruptions (MIT 7.005, 92.0%). However, compliance testing
staff needed to improve medication continuity for patient layovers at the institution (MIT
7.006, 60.0%). Analysis of the compliance data showed the low score was mostly due to
patients not receiving their medication at the next dose interval. As with compliance testing,
our clinicians found new patient arrivals received their medications without a break in
continuity.
Compliance testing showed CTF performed very well with ensuring providers evaluated new
patient arrivals within required time frames (MIT 1.002, 92.0%). However, specialty services
appointments for patients who arrived to CTF intermittently occurred within required time
frames (MIT 14.010, 55.0%). Analysis of the compliance data showed specialty appointments
either did not occur or were not scheduled timely.
Transfers Out
Our clinicians reviewed nine transfer-out events and found two deficiencies in which nursing
did not communicate the patients’ pending specialty appointments.35 Compliance testing
showed CTF performed excellently with placing required medications and documents in the
transfer packets (MIT 6.101, 100%). Our clinicians reached similar findings.
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 a strain on the institution’s resources. In addition, because these
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.
34 Transfer-in deficiencies occurred in cases 26 and 27.
35 Transfer-out deficiencies occurred in cases 31 and 41.
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Our clinicians reviewed 21 events in which patients returned from a hospitalization or
emergency room encounter and identified 14 deficiencies, three of which were significant.36
Both compliance testing and our case review clinicians found CTF performed very well with
ensuring patients received follow-up appointments after hospitalizations or emergency
room encounters (MIT 1.007, 95.8%). CTF also performed well in timely retrieving and
scanning hospital records (MIT 4.003, 90.0%), and providers usually reviewed hospital
reports within five calendar days of discharge (MIT 4.005, 80.0%).
Nursing generally performed complete assessments and interventions; however, our
clinicians found three deficiencies related to nursing assessments when patients returned
from hospitalizations, and one deficiency related to documentation.37 The following is an
example:
• In case 22, the patient returned from the community hospital and complained of
generalized abdominal pain. However, the nurse did not palpate the patient’s
abdomen or subjectively assess the date of the patient’s last bowel movement.
Compliance testing showed CTF performed poorly with maintaining medication continuity
for patients who returned from hospitalizations or emergency room encounters (MIT 7.003,
32.0%). Analysis of the compliance data showed, in eight out of 25 case samples, patients
received their medications up to five days late, including antibiotics and medications for
blood pressure, cholesterol, seizures, and diabetes.
Our clinicians found five deficiencies related to medication continuity for hospital returns,
one of which was significant.38 Please see the Medication Management indicator for further
discussion.
Clinician On-Site Inspection
Case review toured the R&R unit and interviewed the R&R RN. The nurse shared CTF staffed
one RN in R&R each shift and a certified nurse’s assistant (CNA) on the afternoon shift. The
nurse was knowledgeable about the transfer process, including reconciliation of medications
and pending specialty appointments. The nurse stated nursing staff assessed an average of
three to four patients daily for transfer-ins and three to four patients daily for transfer-outs.
Furthermore, the nurse shared R&R nurses assisted the TTA RNs with assessing and
screening patients returning from off-site specialty appointments and hospitalizations,
which could average 20 patients at a given time. The nurse expressed challenges in the R&R
while screening patients upon return from off-site specialty appointments or
hospitalizations because the patients experienced long wait times due to only one nurse
assigned to the task. CNAs assisted with taking vital signs during the screening process when
available. The nurse reported they had a good working relationship with their supervisors
and custody staff.
36 Hospital return deficiencies occurred in cases 1, 2, 19–22, 24, and 42. Significant deficiencies occurred in cases
20, 24, and 42.
37 Nursing assessment and documentation deficiencies occurred in cases, 1, 21, and 22.
38 Medication deficiencies relating to hospital returns occurred in cases 2, 19, 20, 22, and 42. Significant deficiencies
occurred in case 20.
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Compliance On-Site Inspection
R&R nursing staff ensured both of the two patients transferring out of the institution on the
day of our inspection had their required medications, transfer documents, and assigned
durable medical equipment (MIT 6.101, 100%).
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Compliance Score Results
Table 11. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Did nursing
staff complete the initial health screening and answer all screening 12 13 0 48.0%
questions within the required time frame? (6.001)
For endorsed patients received from another CDCR institution: When
required, did the RN complete the assessment and disposition section of
the initial health screening form; refer the patient to the TTA if TB signs and 25 0 0 100%
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: If the patient
had an existing medication order upon arrival, were medications 7 0 18 100%
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 transfer packet 2 0 0 100%
required documents? (6.101)
Overall percentage (MIT 6): 87.0%
Source: The Office of the Inspector General medical inspection results.
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Table 12. 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 23 2 0 92.0%
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 within the 23 1 1 95.8%
required time frame? (1.007)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 18 2 5 90.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 20 5 0 80.0%
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 patient 8 17 0 32.0%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
23 2 0 92.0%
medications continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 6 4 0 60.0%
administered or delivered without interruption? (7.006)
For endorsed patients received from another CDCR institution: If the
patient was approved for a specialty services appointment at the sending
11 9 0 55.0%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no specific recommendations for this indicator.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in administering
prescription medications on time and without interruption. The inspectors examined this
process from the time a provider prescribed medication until the nurse administered the
medication to the patient. In addition to examining medication administration, our
compliance inspectors also tested many other processes, including medication handling,
storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (47.5%)
Case review found CTF’s performance was sufficient for this indicator. Our clinicians found
staff often timely administered chronic care and new prescription medications, and
performed excellently managing medications for patients who transferred into and out of the
institution. However, we identified opportunities for improvement in medication continuity
in one specialized medical housing case and in five cases for patients returning from the
hospital. Factoring all the information, the OIG rated the case review component of this
indicator adequate.
Compliance testing showed CTF had a mixed performance in medication management. Staff
performed excellently in employing general security, storing narcotic medications in
medication rooms, and providing medications for patients transferring within the institution.
However, staff needed improvement in timely providing chronic care medications, newly
ordered medications, hospital discharge medications, and medications for patients en route
to another institution, but who layover at CTF. Based on the overall compliance score result,
the OIG rated this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 135 events in 28 cases related to medications and found 25 medication
deficiencies, four of which were significant.39
New Medication Prescriptions
Our clinicians found CTF performed very well with new prescription medications. We found
four deficiencies in two cases where the patients received their newly prescribed medication
between one to two days late.40 In contrast, compliance testing showed CTF only occasionally
administered new medications timely (MIT 7.002, 44.0%). Compliance data case samples
showed nurses delivered most newly prescribed medications up to four days late, including
antibiotics, and medications to treat high blood pressure, pain, and a diabetes.
39 Medication deficiencies occurred in cases 2, 8, 10, 11, 15, 17, 19–22, 41, and 42. Significant deficiencies occurred
in cases 2, 15, and 20.
40 New medication deficiencies occurred in cases 17, 22, and 42.
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Chronic Medication Continuity
Our clinicians found CTF performed well with ensuring patients received their chronic
medications timely. We identified four deficiencies, one of which was significant.41 The
following is the significant deficiency:
• In case 15, the patient was scheduled to receive cholesterol medication;
however, the patient received the medication nine days late.
In contrast, compliance testing showed CTF performed poorly for chronic care medication
continuity (MIT 7.001, 11.1%). Analysis of the compliance testing data showed, in 16 out of
18 case samples, the pharmacy did not timely fill and dispense medications as ordered,
including medications for blood pressure, diabetes, and cholesterol.
Hospital Discharge Medications
Our clinicians identified a pattern of deficiencies in which staff did not timely administer
medications for patients returning from a hospitalization.42 The following is a significant
deficiency:
• In case 20, the patient returned from a hospitalization but did not receive
chronic care medications for blood pressure, diabetes, and acid reflux disease.
The medication administration record showed the patient received the
medications 31 days late.
Compliance testing showed CTF performed poorly with maintaining medication continuity
for patients who returned from hospitalizations or emergency room encounters (MIT 7.003,
32.0%). Please see the Transfer indicator for further discussion.
Specialized Medical Housing Medications
Our clinicians found seven medication deficiencies in specialized medical housing, two of
which were significant. The following is an example:
• In case 2, the nurses did not always administer the patient’s scheduled insulin
or obtain blood sugar checks per sliding scale, as ordered, for this patient, who
was insulin dependent for diabetes.
Compliance testing showed CTF performed poorly with timely making available and
administering medications upon patient admission (MIT 13.003, 30.0%). Compliance data
showed, in seven out of 10 case samples, most patients received their medications from
several minutes to two days late, including an antibiotic and medications for blood pressure,
seizures, cholesterol, and pain.
41 Chronic medication deficiencies occurred in cases 15, 22, and 42. Significant deficiencies occurred in case 15.
42 Medication deficiencies related to hospital returns occurred in cases 2, 19, 20, 22 and 42. A significant deficiency
occurred in case 20.
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Transfer Medications
Our clinicians found CTF performed excellently with maintaining medication continuity for
patients who transferred into and out of the institution.
Compliance testing showed CTF performed excellently with maintaining medication
continuity for patients who transferred into the institution (MIT 6.003, 100%) and found
patients who transferred within the institution almost always received their medications
timely (MIT 7.005, 92.0%). However, compliance testing showed patient who laid over at CTF
while en route to another institution only intermittently received their medications without
interruption (MIT 7.006, 60.0%). Please see the Transfer indicator for further discussion.
Medication Administration
Compliance testing showed CTF performed sufficiently with ensuring tuberculosis (TB)
medications were administered as ordered (MIT 9.001, 80.0%). However, the nurses rarely
conducted weekly monitoring for patients on TB medications and frequently did not assess
for any signs and symptoms (MIT 9.002, 8.0%).
Clinician On-Site Inspection
During the on-site inspection, case review clinicians interviewed the medication nurses in X-
wing and North A clinic. The nurses were knowledgeable about the medication process. We
found North A clinic had a good keep-on-person (KOP) medication process to ensure patients
were notified when they had medication refills available. The medication nurses explained
patients who have KOP medications would receive a ducat that stated the patient had four
days to pick up their medications.43 They received an additional ducat prior to the fourth day
as a last call before staff returned the medication to the pharmacy. The medication nurses
reported they did not always attend huddles due to administrating medications at the time
the huddles occur. However, they communicated any medication concerns by messaging the
provider and routinely communicated with the clinic LVN coordinator and the RN. We also
attended the clinic huddles and found good communication regarding medication
compliance and expiring medications.
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in all eight applicable
clinic and medication line locations (MIT 7.101, 100%).
CTF appropriately stored and secured non-narcotic medications in four of 10 clinic and
medication line locations (MIT 7.102, 40.0%). In six locations, we observed one or more of
the following deficiencies: the medication storage cabinet was disorganized; nurses did not
maintain unissued medications in original labeled packaging; the treatment cart log was
missing daily security check entries; and medications were not securely stored as required
by CCHCS policy.
Staff kept medications protected from physical, chemical, and temperature contamination in
five of the 10 clinic and medication line locations (MIT 7.103, 50.0%). In three locations, staff
43 A ducat is a pass that allows patients to move around in an institution.
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did not consistently record the room temperatures. In the remaining two locations, the
medication refrigerator was unsanitary.
Staff successfully stored valid, unexpired medications in eight of the 10 medication line
locations (MIT 7.104, 80.0%). In two locations, nurses did not label the multi-use
medications as required by CCHCS policy.
Nurses exercised proper hand hygiene and contamination control protocols in only one of six
applicable locations (MIT 7.105, 16.7%). In five locations, some nurses neglected to wash or
sanitize their hands before donning gloves, before administering medications, or before each
subsequent regloving when gloves were compromised.
Staff in all medication preparation and administration areas demonstrated appropriate
administrative controls and protocols (MIT 7.106, 100%).
Staff in two of six applicable medication areas used appropriate administrative controls and
protocols when distributing medications to their patients (MIT 7.107, 33.3%). In four
locations, we observed one or more of the following deficiencies: medication nurses did not
distribute medications to patients within the required time frame; medication nurses did not
always verify patients’ identification by using a picture form of identification or by using a
secondary identifier; and medication nurses did not reliably observe patients while they
swallowed direct observation therapy medications.
Pharmacy Protocols
CTF did not follow general security, organization, and cleanliness management protocols in
its pharmacy (MIT 7.108, zero). At the time of our inspection, the pharmacy’s medication
preparation area was cluttered.
In the pharmacy, staff did not properly store nonrefrigerated medication. Staff stored
medications in an incorrectly labeled container (MIT 7.109, zero).
The institution properly stored refrigerated or frozen medications in the pharmacy (MIT
7.110, 100%).
The pharmacist-in-charge (PIC) did not thoroughly review monthly inventories of controlled
substances in the institution’s clinic and medication storage locations. Specifically, the PIC or
nurse present at the time of the medication area inspection did not complete the medication
area inspection checklists (CDCR 7477). This error resulted in a score of zero for this test
(MIT 7.111).
We examined 25 medication error reports. The PIC timely or correctly processed only 12 of
these 25 reports (MIT 7.112, 48.0%). In 13 reports, the form had no documentation of the
PIC’s determination or findings regarding the error.
Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors also
followed up on any significant medication errors found during compliance testing. We did
not score this test; we provide these results for informational purposes only. At CTF, the OIG
did not find any applicable medication errors (MIT 7.998).
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The OIG interviewed patients in restrictive housing units to determine whether they had
immediate access to their prescribed asthma rescue inhalers or nitroglycerin medications. Of
the applicable patients interviewed, seven of 10 indicated they had access to their rescue
medications. Three of the patients possessed their rescue inhalers; however, for two of these
three patients, the medication was empty at the time of our inspection, and the remaining
patient had an expired rescue medication. We promptly notified the CEO of this concern, and
health care management immediately reissued replacement rescue inhalers to the patients
(MIT 7.999).
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Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
2 16 7 11.1%
or did the institution follow departmental policy for refusals or no‑shows? (7.001)
Did health care staff administer, make available, or deliver new order prescription
11 14 0 44.0%
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 17 0 32.0%
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 delivered to N/A N/A N/A N/A
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
23 2 0 92.0%
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 delivered 6 4 0 60.0%
without interruption? (7.006)
All clinical and medication line storage areas for narcotic medications: Does the
institution employ strong medication security controls over narcotic medications 8 0 2 100%
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 assigned 4 6 0 40.0%
storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution keep nonnarcotic medication storage locations free of contamination in 5 5 0 50.0%
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 the 8 2 0 80.0%
assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ and follow
hand hygiene contamination control protocols during medication preparation and 1 5 4 16.7%
medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 6 0 4 100%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 2 4 4 33.3%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization, and
0 1 0 0
cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
0 1 0 0
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 protocols?
12 13 0 48.0%
(7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the OIG This is a nonscored test. Please see the indicator
find that medication errors were properly identified and reported by the institution?
(7.998) for discussion of this test.
Pharmacy: For Information Purposes Only: Do patients in restricted housing units This is a nonscored test. Please see the indicator
have immediate access to their KOP prescribed rescue inhalers and nitroglycerin
medications? (7.999) for discussion of this test.
Overall percentage (MIT 7): 47.5%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: If the
patient had an existing medication order upon arrival, were medications 7 0 18 100%
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 transfer- 2 0 0 100%
packet required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
20 5 0 80.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 2 23 0 8.0%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 3 7 0 30.0%
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Health care leadership should develop and implement measures to ensure staff
timely make available and administer chronic care medications, newly ordered
medications, community hospital discharge medications, and medications for
patients temporarily housed at the institution. Leadership should implement
remedial measures as appropriate.
• Nursing leadership should develop and implement measures to ensure nursing
staff document administering medications, patient refusals, and no-shows in the
electronic health record in accordance with CCHCS’s policies and procedures.
Leadership should implement remedial measures as appropriate.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
out patients quickly. The OIG rated this indicator solely according to the compliance score.
Case review does not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (71.8%)
CTF had a mixed performance in preventive services. Staff performed well to excellently in
administering TB medications, screening patients annually for TB, offering patients an
influenza vaccine for the most recent influenza season, and offering colorectal cancer
screening for patients from ages 45 through 75. However, staff performed poorly in
monitoring patients on TB medications and only sporadically offered required
immunizations to chronic care patients. These findings are set forth in the table on the next
page. Based on the overall compliance score result, the OIG rated this indicator inadequate.
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Compliance Score Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
20 5 0 80.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 2 23 0 8.0%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
25 0 0 100%
(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 patient
25 0 0 100%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients? (9.008) 3 4 18 42.9%
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): 71.8%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should develop and implement measures to ensure the
nursing staff monitor patients who are receiving TB medications according to
CCHCS policy.
• Medical leadership should determine the root cause(s) for challenges to timely
providing vaccinations to chronic care patients and should implement remedial
measures as appropriate.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care delivered by the institution’s
nurses, including registered nurses (RN), licensed vocational nurses (LVN), psychiatric
technicians (PT), certified nursing assistants (CNA), and medical assistants (MA). Our
clinicians evaluated nurses’ performance in making timely and appropriate assessments and
interventions. We also evaluated the institution’s nurses’ documentation for accuracy and
thoroughness. Clinicians reviewed nursing performance across many clinical settings and
processes, including sick call, outpatient care, care coordination and management,
emergency services, specialized medical housing, hospitalizations, transfers, specialty
services, and medication management. The OIG assessed nursing care through case review
only and performed no compliance testing for this indicator.
When summarizing 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.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
Our clinicians found overall satisfactory nursing performance for this indicator. We found
nurses generally performed appropriate assessments and interventions for transfers and in
specialized medical housing and the outpatient clinic setting. In addition, CTF nursing
performance was sufficient in medication management. However, we identified
opportunities for improvement with nursing assessments and interventions. Factoring all
the information, the OIG rated this indicator adequate.
Case Review Results
We reviewed 257 nursing encounters in 40 cases. Of the nursing encounters we reviewed, 94
occurred in the outpatient setting and 50 were sick call requests. We identified 62 nursing
performance deficiencies, 12 of which were significant.44
Outpatient Nursing Assessment and Interventions
A critical component of nursing care is the quality of nursing assessment, which includes
both subjective (patient interviews) and objective (observation and examination) elements.
OIG clinicians identified 16 deficiencies related to nursing assessments in the outpatient
clinic, three of which were significant.45 Nurses generally provided appropriate nursing
assessments and interventions. However, we found opportunities for improvement with
44 Deficiencies occurred in cases 1–4, 8, 11, 15–22, 24–27, 31, 32, and 40–42. Significant deficiencies occurred in
cases 1–4, 8, 11, 20, 21, 24, and 42.
45 Outpatient nursing deficiencies occurred in cases 1, 11, 15, 16, 19, 20, 24, 32, and 40. Significant deficiencies
occurred in cases 11, 20, and 24.
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nurse sick call triage. We found nurses did not always evaluate the patient the same day for
urgent complaints or did not schedule a follow-up appointment with the provider when the
patients’ conditions warranted. The following are two examples:
• In case 11, the sick call nurse evaluated the diabetic patient who complained of
loose bloody stools for four days. The patient thought it was related to
hemorrhoids or a side effect from a prescribed medication, dulaglutide.46
However, the nurse did not co-consult with the provider for further evaluation
or schedule a follow-up appointment.
• In case 24, the nurse triaged a health care request for a patient who complained
of muscle pain, bloody stool, irregular heart rate, and headache. The patient was
on a blood thinner medication and should have been seen the same day.
However, the patient was not seen until two business days later.
Complete and accurate nursing documentation is an essential component of patient care.
Without proper documentation, health care staff can overlook changes in patients’
conditions. CTF staff generally documented care appropriately. OIG clinicians identified five
deficiencies related to nursing documentation. The following is an example:
• In case 15, the patient complained of a nonhealing right knee wound. The nurse
assessed the patient and obtained a one-time order for wound care. However,
the nurse did not document a description of the wound, the treatments
provided, or type of dressing applied.
Emergency Services
We reviewed 61 urgent or emergent events and found 48 deficiencies, 15 of which were
significant. Nurses mostly responded promptly to emergent events and initiated CPR timely.
However, nursing assessments, interventions, and documentation needed improvement,
which is detailed further in the Emergency Services indicator.
Hospital Returns
We reviewed 21 events that involved returns from off-site hospitals or emergency room
encounters. CTF nurses generally performed complete nursing assessments and
interventions, which are detailed further in the Transfers indicator.
Transfers
Our clinicians reviewed 10 cases involving the transfer-in and transfer-out process. We found
nurses performed well overall in the transfer process. The nurses mostly completed the
initial healthcare screening form and scheduled nurse and provider appointments timely.
Please refer to the Transfers indicator for further details.
46 Dulaglutide is a medication used to lower blood sugar levels for adults with type 2 diabetes.
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Specialized Medical Housing
Our clinicians reviewed five cases with a total of 89 events. Nurses generally performed
complete assessments and evaluated the patients frequently. Please refer to the Specialized
Medical Housing indicator.
Specialty Services
We reviewed 12 cases in which patients returned from off-site specialty services
appointments or consultations. Nurses performed well in the Specialty Services indicator.
Our clinicians identified only two deficiencies related to nursing assessments and
documentation.47 These deficiencies did not impact the overall care of the patient.
Medication Management
OIG clinicians reviewed 135 events involving medication management and found nurses
generally administered patients’ medications as prescribed. Please refer to the Medication
Management indicator for additional details.
Clinician On-Site Inspection
OIG clinicians interviewed nurses and nursing supervisors in the TTA, the OHU, R&R,
outpatient clinics, and medication clinics. We attended huddles in the central building and
North A clinics. The huddles were informative, well organized, and collaborative. At the time
of the inspection, staff reported no appointment backlogs for the provider, the RN, or the LVN
care coordinator lines. The clinic RNs assessed an average of 12 to14 patients per day, and
the providers evaluated an average of 8 to10 patients per day.
OIG clinicians discussed some deficiencies regarding nebulizer breathing treatments
administered by the LVN. We interviewed the LVN care coordinators and found they
performed patient nebulizer breathing treatments for patients who had an as needed order.
The nurses shared they performed pre- and post-peak flow readings to evaluate medication
effectiveness and would defer to the clinic RN for any further assessment as needed.
The nurses and the LVNs reported they felt supported by nursing leadership and had a good
working relationship with custody staff. Furthermore, the nurses shared they had a
collaborative patient care team, and they worked well together.
47 Minor nursing deficiencies related to off-site specialty returns occurred in cases 17 and 25.
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Recommendations
• Nursing leadership should ensure nurses assess patients with urgent
complaints the same day and notify the providers when patients’ conditions are
warranted. Leadership should implement remedial measures as appropriate.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of care 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 examined provider performance across several clinical
settings and programs, including sick call, emergency services, outpatient care, chronic care,
specialty services, intake, transfers, hospitalizations, and specialized medical housing. We
assessed provider care through case review only and performed no compliance testing for
this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
CTF providers delivered poor care, similar to their performance in Cycle 6. Although
providers documented sufficiently and delivered good continuity, OIG clinicians found many
areas needing improvement. We identified instances of poor provider assessments and
decision-making as well as physical examinations not performed. Furthermore, lapses of
provider care in the specialized medical housing unit with untimely physician rounding,
missed or inaccurate patient assessments, and poor medical decision-making negatively
affected patients. We also found providers did not thoroughly review patient medical
records. Lastly, providers made errors with specialty services. After careful consideration of
all these factors, the OIG rated this indicator inadequate.
Case Review Results
OIG clinicians reviewed 112 medical provider encounters and identified 84 deficiencies, 39
of which were significant. In addition, we reviewed the quality of care in 20 comprehensive
case reviews. Of these 20 cases, we found 13 adequate and seven inadequate.48 Two of the
inadequate cases related to CTC patients.
Outpatient Assessment and Decision-Making
Providers generally made good assessments and sound decisions; however, we identified
many deficiencies.49 The following are significant examples:
• In case 21, the nurse contacted the on-call provider about an asthmatic patient
with a history of smoking an average of a pack of cigarettes a day for 30 years,
who complained of having had a productive cough for eight days. The nurse
heard coarse crackles in the patient’s right and left upper lung lobes, which
could have indicated pneumonia or another infectious process that might have
48 Deficiencies occurred in cases 1, 2, 9–13, 15, 17–24, 41, and 42. Significant deficiencies occurred in cases 2, 9, 11–
13, 17, 18, 21, 22, and 24.
49 Decision-making deficiencies occurred in cases 1, 9, 17, 19, 21–24, and 42. Significant deficiencies occurred in
cases 9, 21, 22 and 24.
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required an antibiotic. The provider ordered a cough suppressant and topical
sore throat relief medication without further monitoring or additional
assessment of the patient, despite the patient’s high risk for complications.
• In case 22, the patient returned from coronary artery bypass surgery, that was
performed five days earlier.50 A patient returning from this surgery would not be
able to perform the regular activities of daily living, including walking extremely
long distances or obtaining his own meals. The provider ordered the patient to
be sent to a regular housing unit instead of specialized medical housing, where
the patient’s health and physical safety could be closely monitored and
assistance be given as needed. The patient was not moved to specialized medical
housing until nearly two days later when the patient requested further medical
care.
• Also in case 22, neither of the two providers who were involved in the patient’s
post-surgery care ordered pain medication promptly. The patient did not
receive his first dose of pain medication until nearly two days after his return
from the hospital.
• In case 24, the nurse contacted the provider about the patient, who complained
of head and neck pain, bloody stool for four days, abdominal pain, and irregular
heartbeats. The patient was on immunosuppressant and blood thinning
medications. The provider ordered the patient be seen for his complaints two
days later instead of being seen immediately.
We also identified a pattern of providers not performing appropriate physical exams. The
following are examples:
• In case 17, the provider documented the patient’s bilateral lower extremity
swelling was controlled; however, the provider did not examine the patient’s
lower extremities.
• In case 22, the provider documented an assessment and plan for the patient’s
knee pain and ordered a knee x-ray and brace. The provider did not document
any knee complaints in the review of systems or history of present illness and
did not perform a specific knee examination. The record was not clear as to
what the medical indications were for this x-ray or the brace.
• In case 23, the provider evaluated the cancer patient for right rib pain. The
provider documented the patient’s pain was likely from the liver; however, the
provider did not document a musculoskeletal examination, including ribs or
chest wall, or an abdominal examination.
50 A coronary artery bypass surgery is a major surgery to restore blood flow around a blocked heart artery by taking
a healthy blood vessel from another part of the body and using it to create a new path for blood flow in the heart.
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Outpatient Review of Records
Providers usually endorsed diagnostic studies and specialty reports timely. However, we
identified a pattern of providers not thoroughly reviewing patient electronic health records
and identified significant deficiencies.51 The following are examples:
• In case 18, the provider documented the patient, who had a history of aortic
valve replacement, was on a blood thinning medication; however, the patient
had not been on the medication since 2020.
• Also in case 18, the patient was scheduled to see a provider for the patient’s
concerns about worsening memory. The provider did not review the patient’s
chart appropriately and, therefore, did not understand the reason for the
appointment, mistaking it for a duplicate of a recent chronic care appointment.
The provider cancelled the appointment without seeing the patient.
Consequently, the patient was not assessed for concerns about worsening
memory.
• In case 22, the provider ordered for the patient to return to the yard from the
specialized medical housing unit after a heart bypass surgery. The provider
started the patient on amiodarone for 90 days; however, in the hospital
discharge report, the cardiothoracic surgeon clearly recommended the patient
take amiodarone only for a total of 24 days after discharge.52 The medication
should have been stopped as recommended by the cardiovascular surgeon. It
was continued for over seven months without appropriate monitoring because
the provider did not thoroughly review the patient’s hospital discharge report.
Emergency Care
In the 61 emergency events OIG clinicians reviewed, providers were available for
consultation with TTA nursing staff and usually documented emergency events well.
Although providers generally managed patients appropriately, we found providers
occasionally misdiagnosed medical problems or ordered incorrect modes of emergency
transport.53 Significant deficiencies are described below:
• In case 2, the provider sent the diabetic patient with end-stage liver disease,
who had severe abdominal pain and lethargy, to the hospital by basic life
support transport urgently rather than emergently. The patient did not leave
CTF until one hour after the lethargy was documented. In addition, the provider
did not order a finger stick blood glucose check on this insulin dependent
diabetic patient with lethargy, delaying the possible diagnosis of low sugar.
When hospital staff checked the patient's finger stick blood glucose, the blood
glucose was, in fact, very low and the patient required medical intervention.
51 Review of records deficiencies occurred in cases 18, 21, 22, and 24.
52 Amiodarone is a medication used to treat and prevent serious abnormal heart rhythms. It is used to restore
normal heart rhythm and maintain a regular, steady heartbeat. Amiodarone can cause side effects on the heart, liver,
thyroid, and lungs.
53 Provider related emergency care deficiencies occurred in cases 1–4, 7, 8, 13, 19–21, 24, and 42. Significant
deficiencies occurred in cases 2, 7, 13 and 21.
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• Also in case 2, the nurse documented contacting the provider about the patient’s
return from the hospital after a procedure to drain fluid from the patient’s
abdomen. The nurse reported the patient was confused, disoriented, and had an
elevated heart rate. Patients who undergo this procedure can develop significant
electrolyte imbalances, and the provider should have ordered laboratory tests to
check for electrolytes. In addition, the provider did not order the patient to be
sent to a higher level of care until over one hour later, and ordered for transport
back to the hospital urgently rather than emergently, which was medically
indicated. This action delayed appropriate emergency care to the patient. The
patient did not leave CTF via ambulance until nearly three hours after staff
identified the patient’s altered mental status.
OIG clinicians found, when the EMRRC reviewed emergency events, the committee often
missed critical findings. Our clinicians further found, because the CTF CME or designee in the
EMMRC often did not perform clinical reviews of emergency events as required by policy, the
CME did not identify these missed findings or take remedial measures. We discuss this
further in the Emergency Services indicator.
Chronic Care
Providers usually managed patients’ chronic health conditions appropriately. However, we
identified 18 deficiencies in chronic care management, 10 of which were significant.54
Examples of significant deficiencies are described below:
• In case 11, the nurse and the provider discussed the patient’s request to change
the dosage time of one of his diabetes medications due to severe diarrhea after
this medication’s injection. The nurse documented the provider agreed to
change the medication dose time to 11:00 a.m. and would order a provider
follow-up appointment to assess the medication change. The provider ordered
the medication change but did not order the follow-up appointment. This placed
the patient at risk of worsening diabetes or electrolyte imbalances from the
diarrhea.
• Later in case 11, the patient submitted more medical requests for help with the
continued diarrhea. Eventually the patient refused the medication. A provider
follow-up appointment was finally scheduled; however, the provider did not
evaluate the patient until 20 days after the patient’s initial complaint of severe
diarrhea. The provider documented the patient had diarrhea and blood in the
stool but did not document an assessment of the patient’s bloody stool, which
could have been related to more significant problems such as internal bleeding.
The provider also reduced the patient’s medication but did not order a provider
follow-up appointment to ensure the patient’s negative side effects from the
medication had resolved and the patient’s diabetes did not worsen.
• In case 12, the provider reviewed the diabetic patient’s very elevated
hemoglobin A1c level, which indicated uncontrolled diabetes.55 The provider
sent a patient notification letter stating a chronic care appointment had been
54 Chronic care deficiencies occurred in cases 1, 10–12, 17, 21, 22, and 24. Significant deficiencies occurred in cases
11, 12, 21, and 24.
55 Hemoglobin A1c is a blood test that measures the average blood glucose over the previous 12 weeks.
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scheduled; however, the provider did not order the appointment. Five weeks
later, a different provider ordered the necessary follow-up chronic care
appointment. The provider evaluated the patient more than three months after
the abnormal hemoglobin A1c test result was available. In the interim, the
patient’s diabetes was out of control, increasing the risk of diabetic related
complications. The provider should have evaluated the patient sooner.
• In case 21, the nurse contacted the provider by phone about a patient who was
released from a seven-day hospital stay for asthma and acute respiratory failure.
The patient complained of continued shortness of breath. The provider
documented the patient’s recent hospitalization, continued symptoms, and a
need for a follow-up appointment with a provider for the next day. The provider
did not order the follow-up appointment and did not evaluate the patient. The
patient was not scheduled with a provider for reassessment until almost one
month later.
Specialized Medical Housing
Although providers were efficient at completing new patient admission history and physical
examinations within required time frames, OIG case review clinicians found specialized
medical housing providers delivered poor care to the patients. OIG clinicians reviewed 29
provider events in five specialized medical housing cases and found 20 provider
performance deficiencies, 11 of which were significant. We identified delayed provider
rounding, missed or poor patient assessments, poor medical decision making, and missing or
poor documentation. We discuss this further in the Specialized Medical Housing indicator.
Specialty Services
OIG clinicians identified 14 deficiencies, eight of which were significant and related to poor
decision making by the CTF providers. These deficiencies included ordering specialty
services for inappropriate time frames, not ordering needed specialty services, or not
following specialists’ recommendations.56 The following are examples of significant
deficiencies:
• In case 11, the patient was on treatment for a fungal infection called
coccidiomycosis. When the patient’s chest x-ray and coccidiomycosis laboratory
results normalized, the provider did not discontinue the patient’s antifungal
medication or timely consult an infectious disease specialist for further
recommendations. The patient remained on this medication unnecessarily until
another provider discontinued it more than six months later. The provider did
not receive any recommendations from an infectious disease specialist until the
provider ordered an eConsult more than four months later.57
• In case 17, the provider endorsed a hematology specialty report with
recommendations for the patient be referred to a tertiary care hematology
56 Deficiencies occurred in cases 1, 11, 17, 22, and 24. Significant deficiencies occurred in cases 11, 17, 22, and 24.
57 eConsult is an electronic specialty consulting service whereby providers can inquire of specialists about medical
questions and receive advice and recommendations for patient care.
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specialist to assist in his care since his treatment was failing.58 The provider did
not order the referral until five weeks later, delaying care to the patient.
• Also in case 17, the hematology specialist evaluated the patient on three
separate occasions over a seven-month period. At each appointment, the
hematology specialist documented the patient should not receive aspirin if his
platelet count was over a certain level due to the high risk of bleeding. During
most of this period, the patient’s platelet count was over this level. The provider
did not discontinue aspirin, as recommended by the specialist, and did not
document why the provider did not follow the recommendations. The provider
did not discontinue the aspirin for approximately eight months, which placed
the patient at medical risk.
Outpatient Documentation Quality
Documentation is important because it shows the provider’s thought process during clinical
decision-making. Except for the specialized provider performance mentioned above,
providers usually documented accurately in the outpatient and emergency settings.
Patient Notification Letters
After providers endorsed diagnostic studies, they usually sent notification letters to patients.
However, we identified 54 deficiencies related to incomplete letters, which did not contain all
the components required by CCHCS policy.59
Provider Continuity
CTF offered good provider continuity. OIG clinicians identified only one case with poor
clinical provider continuity.60
Clinician On-Site Inspection
We met with the CME, the CP&S, and providers to discuss provider related issues. The CME
had worked at CTF for many years while the CP&S was relatively new to his position,
promoting from a line physician position. They reported the CP&S evaluated patients in the
clinic and took calls due to physician staffing. The CME also evaluated patients and
responded to calls as needed.
CTF had seven clinics, an OHU, a TTA unit, and on-site specialty services. A part-time
physician was assigned to the OHU two days a week, and other providers were assigned the
rest of the week.
To help retain staff, medical leadership offered a work schedule of four ten-hour workdays,
which the providers reported to be very happy with. Providers were assigned to teams of
two, and they coordinated regular day off coverage and leave with each other.
58 A hematology specialist evaluates and treats disorders of the blood.
59 Incomplete patient test result notification letters occurred in cases 2, 11–17, 20–25, 41, and 42.
60 Poor provider continuity occurred in case 11.
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Medical leadership had implemented several creative uses of Microsoft Teams for huddles
and staff communication. Each morning before clinic huddles and clinics started, the
providers met to discuss events from on-call the night prior. The on-call provider completed
a clear, organized spreadsheet of all medically significant calls that had occurred. The
spreadsheet included the patient’s identifying information and which primary care provider
was responsible for the patient’s care. In addition, the on-call provider documented the
issues addressed and follow-up needed. This documentation was very helpful in ensuring
patient care occurred after emergencies because it allowed both the primary care provider
and the partner physician responsible for that yard to understand which post-emergency
patients needed to be seen. The format was clear and comprehensive, which was important
due to the physician alternate work week schedule. Using Microsoft Teams also allowed the
physicians to communicate quickly and efficiently with nursing staff about patient care
issues and to document histories and thought processes in Teams regarding patients who
had presented to the on-call provider overnight. The one concern identified with using
Teams was these communications were then not included in the patient’s electronic medical
chart.
When asked what challenges the institution faced, medical leadership mentioned hiring and
retaining providers was difficult. During the case review period in 2023, CTF had three to
four vacant full-time provider positions. CTF neighbors with Salinas Valley State Prison
(SVSP), whose physicians receive a 15 percent pay incentive for similar work. This may have
discouraged providers from staying at or applying to CTF if SVSP had open positions.
Moreover, CTF is in Monterey County, an area with a higher cost of living, but no increased
cost of living adjustment is offered to prospective staff. Medical leadership expressed general
difficulty recruiting physicians to correctional facilities.
To accommodate the shortage of physicians, CTF leadership had consolidated the central
yard clinics from four clinics to three, increasing the patient load to the providers. The
providers worked extended hours to meet patient care demands. The CP&S and the CME also
both worked patient care lines to help reduce backlogs and took on-call duties to reduce the
this burden on the providers. One registry provider was on site. B1 Yard was essentially
manned part-time by different physicians for at least six months, resulting in poor continuity
of care on that unit because of the loss of a physician. Two providers were long-term
telemedicine physicians who worked on-site at CTF prior to moving to telemedicine. Other
telemedicine providers intermittently provided coverage as well. The OHU provider only
worked part-time and was on-site two days per week, but was also assigned to cover the
restrictive housing unit.
Providers reported using laptops for home calls. They expressed they could obtain more
history and offered improved patient care due to the use of laptops. One provider mentioned
having the laptop allowed a more flexible schedule, since they could complete entering
information into EHRS from home.
Providers expressed satisfaction and felt supported and heard by their medical leadership.
Their main concern was the continued provider shortage, which some reported made taking
calls unsustainable in the long term and caused burn out.
The CP&S demonstrated a new patient notification letter system CCHCS developed to help
overcome the continued deficiencies in missing elements in patient results notification
letters. In the demonstration we received, the provider was required to generate the letter,
then later endorse the results separately in the EHRS. Previously, the provider endorsement
occurred concurrently with patient notification letter generation.
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Recommendations
• Medical leadership should analyze the root cause(s) of poor assessments,
emergency care, medical record review, specialty follow-up, documentation,
specialized medical housing care, and chronic condition management and
should implement remedial measures as appropriate.
• Medical leadership should develop strategies to ensure complete and thorough
review of emergency cases and implement remedial measures as appropriate.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing, monitoring,
and intervening for medically complex patients requiring close medical supervision. Our
inspectors also evaluated the timeliness and quality of provider and nursing intake
assessments and care plans. We assessed staff members’ performance in responding
promptly when patients’ conditions deteriorated and looked for good communication when
staff consulted with one another while providing continuity of care. Our clinicians also
interpreted relevant compliance results and incorporated them into this indicator. At the
time of our inspection, CTF’s specialized medical housing consisted of an outpatient housing
unit (OHU).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Adequate (80.0%)
In case review, CTF’s medical care was mixed for specialized medical housing patients.
Nurses performed satisfactorily overall, as they generally performed good assessments,
completed admission assessments timely, and conducted daily rounds. However, our
clinicians identified a pattern of incomplete admission assessments and lapses in provider
notifications for patient change of condition. Moreover, provider performance was poor with
questionable medical decisions, missing documentation, and untimely patient evaluations.
Factoring all aspects, the OIG rated the case review component of this indicator inadequate.
Compliance testing similarly showed mixed performance in this indicator. CTF showed poor
medication continuity for newly admitted patients in the OHU. In contrast, providers timely
completed history and physical examinations, and nurses frequently completed initial
assessments within required time frames. Based on the overall compliance score result, the
OIG rated the compliance component of this indicator adequate.
Case Review and Compliance Testing Results
We reviewed 89 OHU events that included 29 provider events and 34 nursing events. Due to
the frequency of nursing and provider contacts in specialized medical housing, we bundle up
to two weeks of patient care into a single event. We identified 42 deficiencies, 17 of which
were significant.61
Provider Performance
Overall, provider performance needed significant improvement as OIG clinicians found
specialized medical housing providers performed poorly in clinical care of the patients. OIG
clinicians reviewed 29 provider events in five specialized medical housing cases and
identified 20 provider performance deficiencies, 11 of which were significant. We rated two
of the five cases inadequate due to poor provider performance. The deficiencies included
61 Deficiencies occurred in cases 2, 20, 22, 41, and 42. Significant deficiencies occurred in cases 2, 22, and 42.
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untimely physician rounding, missing or inaccurate assessments, poor medical decision
making, and lapses in documentation.62 The following are examples of the significant
deficiencies:
• In case 2, the provider evaluated the patient with end-stage liver disease, but
did not address the abnormal laboratory test, which indicated possible hepatic
encephalopathy.63 The provider also did not perform a neurologic assessment
for this condition even though the provider had documented signs of
encephalopathy at the previous appointment. When the patient transferred to
the hospital the next day, the hospital physicians documented the patient
had altered mental status and ordered medication to treat the encephalopathy.
• Also in case 2, the nurse messaged the provider for an acute change in the
patient’s condition of “weeping” legs. The nurse ordered a dressing change, and
the provider cosigned the order two days later. Acute leg weeping can be a sign
of fluid overload or low protein in end-stage liver disease. The provider did not
timely evaluate the patient for this condition.
• Furthermore, in case 2, the provider did not evaluate the patient for 25 days
despite the patient’s active and ongoing symptoms of end-stage liver disease,
frequent hospitalizations, emergency encounters, and messages from nurses.
• In case 22, the provider evaluated the patient who had coronary artery bypass
surgery seven days prior. The patient complained of chest pain, shortness of
breath, and dizziness. The symptoms could have been indicative of a heart
attack. The provider documented the surgeon would be contacted to discuss the
chest pain. However, the provider did not contact the surgeon to obtain further
recommendations on this high-risk patient’s chest pain symptoms, did not
document a review of vital signs for the patient, and did not address the
patient’s symptoms of dizziness.
Provider documentation is critical to ensure covering providers have current information,
especially if the institution does not have a full-time OHU provider, as with CTF. OIG clinicians
identified six instances of providers ordering tests or treatments without documenting the
medical reasoning.64 The providers sometimes also did not examine or assess the patient for
the related symptoms. The following are examples:
• In case 2, the nurse messaged the provider the patient’s blood pressure had
been elevated for the past few days. The provider responded “OK” but did not
document an assessment or decision making in the patient’s electronic medical
record.
• In case 22, the patient, who had undergone coronary artery bypass surgery,
complained of nausea and dizziness. The symptoms could have been related to
62 Cases 2, 22, 41 and 42 involved specialized medical housing providers. Deficiencies occurred in cases 2, 22, 41,
and 42. Significant deficiencies occurred in cases 2 and 22.
63 Hepatic encephalopathy is a brain disorder caused by impaired liver function. Symptoms include altered mental
status, neuromuscular impairment, and coma.
64 Providers did not document medical decision making in cases 2, 22, 41, and 42. Specialized medical housing
provider performance deficiencies occurred in cases 2, 22, 41, and 42. Significant deficiencies occurred in cases 2
and 22.
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heart problems or surgical complications; however, the provider did not
evaluate the patient for these symptoms. Rather, the provider ordered
symptomatic care and did not document a progress note with medical
reasoning, nor assess the patient’s symptoms for potential causes.
• In case 42, the provider evaluated the diabetic patient, who was taking steroid
medications for complaints of phimosis.65 The provider did not document a
history of symptoms or a physical examination. The provider documented this
diagnosis and a treatment of steroids without documenting objective evidence
supporting this was truly the patient’s condition.
Compliance testing showed providers always completed new admission history and
physicals within required time frames (MIT 13.002, 100%), and case review found similar
results.
Nursing Performance
Compliance testing and our clinicians both found CTF performed very well with ensuring
nurses timely completed the initial nursing assessments for newly admitted patients (MIT
13.001, 90.0%). Our clinicians identified 13 deficiencies related to nursing care, two of which
were significant.66 Our clinicians found nurses generally performed good nursing
assessments and conducted daily rounds on the patients. However, we identified a pattern in
four cases where nurses missed components of the admission assessment and, in another
three cases, nurses did not notify the provider when the patient’s condition warranted.67 The
following are examples:
• In case 41, the nurse documented the patient complained of nausea, dizziness,
and pain to the abdominal area with cramping and discomfort. However, the
nurse did not palpate the patient’s abdomen or notify the provider of the change
in condition. Further, the nurse did not reassess the patient for symptom
improvement.
• In case 42, the patient was admitted to the OHU after hospital discharge for
chronic obstructive pulmonary disease.68 However, the nurse did not complete a
thorough admission assessment to include listening to heart sounds or bowel
sounds.
Medication Administration
Compliance testing showed CTF performed poorly with medication continuity for patients
newly admitted to the OHU (MIT 13.003, 30.0%). Our clinicians identified seven deficiencies
related to medication administration, two of which were significant. Please refer to the
Medication Management indicator for further discussion.
65 Phimosis is a medical condition in which the foreskin of the penis cannot be fully retracted over the head of the
penis, leading to discomfort, difficulty in urination, infection, and urinary obstruction.
66 Nursing deficiencies occurred in cases 2, 20, 22, 41, and 42. Significant deficiencies occurred in cases 2 and 42.
67 Deficiencies related to incomplete admission assessments occurred in cases 2, 20, 22, and 42. Deficiencies related
to a lack of provider notification occurred in cases 2, 41, and 42.
68 Chronic obstructive lung disease (COPD) is a chronic and progressive lung disease with damage to the lung and
restrictive airflow.
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Clinician On-Site Inspection
OIG clinicians interviewed the OHU RN and the nursing supervisor. The CTF OHU had 17
medical beds and three additional beds utilized for alternative housing. At the time of our
inspection, the OHU had a census of 17 with an average daily census of 13. The OHU staff
consisted of one RN on morning shift, one LVN on swing shift, one LVN on the night shift as
well as a designated provider assigned two days a week. The TTA RN would cover for nursing
consultation on swing shift and night shift.
The nurses stated they performed nursing rounds twice a day and completed thorough
assessments daily. The nurses reported they received medical supplies and medications
timely, and after hours they used the Omnicell in the TTA for needed medications.69
Compliance On-Site Inspection
At the time of our on-site inspection, the OHU had a functional call light communication
system (MIT 13.101, 100%).
69 An Omnicell is an automated medication dispensing machine.
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Compliance Score Results
Table 16. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Did the registered nurse complete an initial
9 1 0 90.0%
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
10 0 0 100%
required time frame? (13.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 3 7 0 30.0%
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call 1 0 0 100%
system? (13.101)
For specialized health care housing (CTC, SNF, hospice, OHU): Do health
care staff perform patient safety checks according to institution’s local 0 0 1 N/A
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): 80.0%
Source: The Office of the Inspector General medical inspection results.
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`
Recommendations
• Nursing leadership should develop strategies to ensure nurses perform
thorough patient admission assessments and notify providers of any abnormal
changes in patients’ conditions and should implement remedial measures as
appropriate.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. The OIG clinicians
focused on the institution’s performance in providing needed specialty care. Our clinicians
also examined specialty appointment scheduling, providers’ specialty referrals, and medical
staff’s retrieval, review, and implementation of any specialty recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (74.1%)
Case review found CTF delivered satisfactory specialty services for their patients. Specialty
services access was fair, and nurses performed well. In contrast, providers sometimes
performed poorly in ordering specialty referrals within the appropriate priority time frame
and in following specialists’ recommendations. Staff also needed improvement in retrieving
specialty consultation reports. Considering all aspects, the OIG rated the case review
component of this indicator adequate.
Compared with Cycle 6, compliance testing showed CTF still needed improvement in this
indicator. CTF performed very well in providing initial high-priority and routine-priority
specialty services, and in subsequent follow-up appointments for medium-priority and
routine-priority specialty services. However, CTF scored low in providing initial medium-
priority and preapproved specialty services, as well as in timely retrieving and endorsing
specialty reports. Based on the overall compliance score result, the OIG rated this indicator
inadequate.
Case Review and Compliance Testing Results
We reviewed 109 events related to specialty services; 72 were specialty consultations and
procedures and 37 were nursing encounters. We identified 30 deficiencies, 11 of which were
significant.70
Access to Specialty Services
Compliance testing showed CTF performed very well in completing high-priority
appointments (MIT 14.001, 93.3%) and well in providing routine-priority specialty
appointments within ordered time frames (MIT 14.007, 86.7%). However, testing showed
CTF needed improvement in providing medium-priority specialty services (MIT 14.004,
66.7%). OIG clinicians identified seven deficiencies related to specialty access to care, five of
which were significant.71 The following are examples:
70 Deficiencies occurred in cases 1, 2, 11, 12, 17, 18, 22–25, and 41. Significant deficiencies occurred in cases 1, 2, 12,
18, and 22–25.
71 Specialty access deficiencies occurred in cases 2, 12, 18, 22, 41, and 42. Significant deficiencies occurred in cases
2, 12, 18, 22, and 42.
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• In case 18, the provider ordered a cardiology follow-up appointment for a
patient with a history of aortic valve replacement; however, the specialty
appointment occurred almost four months late.
• In case 22, the patient had a four-vessel heart bypass surgery which required a
follow-up appointment from the heart specialist. A provider cancelled the
appointment, but a different provider recognized this error and reordered the
appointment, resulting in a new appointment that was delayed an additional
seven weeks. The patient was not seen by the heart specialist for almost five
months after the surgery occurred.
• In case 42, staff ordered three outstanding specialty appointments for the
patient: an ophthalmology and two pulmonology specialty appointments. The
patient was admitted to the hospital. However, upon the patient’s return from
hospitalization, staff did not appropriately reconcile and reorder these three
appointments. Consequently, the patient either did not timely receive, or did not
receive at all, these specialty services.
Compliance testing indicated CTF needed significant improvement with ensuring transfer
patients from other institutions received their preapproved specialty services within the
originally scheduled time frames (MIT 14.010, 55.0%). OIG clinicians did not identify any
specialty transfer deficiencies in its three transfer-in cases.
CTF struggled with providing patients their subsequent high-priority specialty follow-up
appointments as ordered by the primary care provider (MIT 14.003, 69.2%) but performed
satisfactorily on medium-priority and routine-priority specialty service follow-up
appointments (MIT 14.006, 83.3% and MIT 14.009, 83.3%).
When specialty services were denied, CTF needed improvement with informing patients of
the denial within required time frames (MIT 14.012, 65.0%).
Provider Performance
Compliance testing showed providers sufficiently completed the post-specialty primary care
provider follow-up appointments within required time frames (MIT 1.008, 76.2%). Case
review only found one significant access deficiency with a provider follow-up appointment
after a specialty procedure as follows:
• In case 24, the patient returned from an off-site cardiac MRI. The results were
abnormal, with evidence of previous heart scarring and reduced pumping
function. The patient was scheduled to see his primary care provider 14 days
later to follow up, but this appointment did not occur.
Case review identified 14 provider performance deficiencies related to specialty services;
eight of which were significant. These deficiencies included: providers not ordering
appropriate services for patients leading to delays or omission of care; providers not
contacting specialists to correct an error or address an abnormal finding; and providers not
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following specialists’ recommendations without documenting medical justification.72 The
following are examples:
• In case 22, the provider cancelled a cardiology specialty referral for the patient
who required a cardiology follow-up after his coronary artery bypass surgery
completed eight days prior. The documentation stated the referral was cancelled
because the patient would be scheduled with the “local MD.” This delayed
cardiology specialty follow-up care for the patient.
• Also in case 22, the provider endorsed the cardiothoracic surgeon’s follow-up
report, which documented the patient needed to continue cardiac rehabilitation
after the patient’s cardiac bypass surgery; however, the provider did not order
the cardiac rehabilitation prior to or after the surgeon’s evaluation.
• In case 24, the provider evaluated the patient at a follow-up appointment after a
neurology specialty consultation and nerve conduction test. The test showed
bilateral upper extremity carpal tunnel syndrome and bilateral ulnar
neuropathy.73 The provider did not address the patient’s bilateral carpal tunnel
diagnosis nor discuss positional or conservative care measures to improve the
patient’s symptoms; did not give the patient braces for treatment for the right
wrist (the patient had previously been given a left wrist splint); and did not
discuss bracing options and positional or conservative ulnar neuropathy
treatments with the patient.
We detailed more information in the Provider Performance indicator.
Nursing Performance
Case review found nurses performed well in assessing patients who returned to the CTF
from off-site appointments. We identified only two minor deficiencies.74
Health Information Management
CTF performed variably in obtaining specialty reports timely. Compliance testing showed
CTF frequently scanned reports timely (MIT 4.002, 93.3%). However, compliance testing
found staff needed improvement in retrieving routine-priority, medium-priority, and high-
priority specialty reports, and providers needed improvement in endorsing reports within
required time frames (MIT 14.008, 60.0%, MIT 14.005, 66.7%, and MIT 14.002, 60.0%). OIG
clinicians reviewed 72 specialty consultations or procedures and identified 18 deficiencies
related to health information management, six of which were significant.75 The following are
examples of significant deficiencies:
72 Provider performance deficiencies occurred in cases 1, 11, 17, 22, and 24. Significant deficiencies occurred in
cases 11, 17, 22, and 24.
73 Carpal tunnel syndrome is a disorder caused by pressure on a nerve in the wrist. This may result in hand pain,
numbness, tingling, weakness, and loss of function. Ulnar neuropathy is a disorder of the ulnar nerve, a nerve from
extending from the neck to the hand. Symptoms may occur in the elbow or hand and, similar to carpal tunnel
syndrome, results in pain, numbness, tingling, weakness, and loss of function.
74 The deficiencies occurred in cases 17 and 25.
75 HIM specialty deficiencies occurred in cases 1, 2, 12, 17, 18, and 22–25. Significant deficiencies occurred in cases
1, 2, and 22–25.
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• In case 1, the gastrointestinal specialist performed
esophagogastroduodenoscopy (EGD) and colonoscopy procedures with
biopsies.76 CTF staff scanned the biopsy results from these procedures into the
patient’s electronic health record more than one month later. These biopsy
results could have contained time-sensitive information, such as colon cancer,
and the delay in obtaining the results placed the patient at risk.
• In case 2, a hematology specialist evaluated the patient, but CTF staff did not
scan the specialist’s report until more than nine months later.
• In case 22, a cardiothoracic surgeon evaluated the patient, but CTF staff scanned
the specialist’s report into the patient’s electronic health record nearly 11
months later.77
• In case 23, an RN documented a telemedicine specialty cancer appointment
occurred; however, at the time of the clinician on-site inspection, approximately
seven months later, staff still had not scanned this specialty report into the
patient’s electronic health record.
• In case 25, an interventional radiologist performed a chemoembolization
procedure for the patient.78 However, staff did not obtain the procedure report
until 28 days later.
Clinician On-Site Inspection
During the on-site inspection, we discussed specialty services processes and case review
deficiencies with medical leadership, health information management supervisors, ancillary
staff, diagnostic staff, nurses, and providers.
When asked about difficulties obtaining specialty services, CTF leadership stated no local
specialists for dermatology, podiatry, allergy, audiology, gastroenterology, or orthopedic
surgery were available within the specialist network CCHCS used. For patients requiring
these services, such as a simple hearing test or diabetic toenail care, custody staff must
transport the patients to a contracted provider located far away from CTF. CTF leadership
described using CCHCS telemedicine orthopedic services to determine whether a patient was
a surgical candidate because of a local shortage of contracted orthopedic surgeons during the
review period. CTF leadership further explained, if a patient was a candidate, the patient
would be referred to a different contracted orthopedic surgeon for another initial evaluation
and possibly surgery. While this practice could delay care to the patient, it allowed the
institution to screen whether patients with orthopedic symptoms required the long-distance
transport.
Staff scheduled both on-site and off-site initial specialty appointments according to the
priority level the provider documented on the referral and executive management approved.
Staff scheduled follow-up appointments per the specialist’s recommendations. Leadership
reported, even though a specialist would recommend when a patient should have a follow-up
76 An EGD is an esophagogastroduodenoscopy. In this procedure, the specialist uses a camera to examine the
esophagus and the stomach.
77 A cardiothoracic surgeon performs surgery of the heart, lungs, esophagus, and other organs in the chest.
78 Chemoembolization is a procedure to deliver cancer-treating medication to a tumor while reducing the tumor’s
blood supply.
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specialty appointment, often that specialist was not available during the recommended time
frame, which led to delays in meeting compliance dates.
In regard to our finding that providers entered incorrect priorities on specialty referrals,
both medical leadership and providers reported receiving no special direction regarding
specialty services priority ordering. However, some providers mentioned they knew which
services CTF could not obtain within the high-priority time frames (up to 14 days).
Therefore, they often ordered those as medium-priority (up to 45 days), regardless of the
medical indication.
Staff described reconciling outstanding specialty orders in several situations. For newly
arrived patients with outstanding specialty consultations, if the referral was pending and
scheduled, the UM RN entered and reconciled the order into the CTF system. If a follow-up
specialty services appointment was pending, the CTF providers reconciled the orders. In
addition, if a patient was sent to the hospital for more than 24 hours, the providers had to
ensure outstanding specialty orders prior to hospitalization were reconciled and reordered.
Although the providers are responsible for entering post-hospital specialty reconciliation
orders in EHRS, the UM nursing staff reported they also track those orders to monitor
whether the providers reenter the cancelled specialty services orders upon the patient’s
return and to ensure the compliance date remains the same. If they find no order written, the
UM nursing staff message the providers; however, the providers are primarily responsible.
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Compliance Score Results
Table 17. 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 Request for 14 1 0 93.3%
Service? (14.001)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 9 6 0 60.0%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 9 4 2 69.2%
(14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or Physician Request for 10 5 0 66.7%
Service? (14.004)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 10 5 0 66.7%
frame? (14.005)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 5 1 9 83.3%
(14.006)
Did the patient receive the routine-priority specialty service within 90
calendar days of the primary care provider order or Physician Request for 13 2 0 86.7%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 9 6 0 60.0%
frame? (14.008)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 5 1 9 83.3%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
11 9 0 55.0%
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 specialty
20 0 0 100%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
13 7 0 65.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 74.1%
Source: The Office of the Inspector General medical inspection results.
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Table 18. 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 visits
16 5 24 76.19%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
28 2 15 93.33%
within five calendar days of the encounter date? (4.002)
* 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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Recommendations
• CTF leadership should determine the root cause(s) of challenges to timely
providing specialty appointments and should implement remedial measures as
appropriate.
• CTF leadership should ascertain the challenge(s) to the receiving specialty
reports within required time frames and should implement remedial measures
as appropriate.
• Medical leadership should determine the root cause(s) of providers not
following specialists’ recommendations or not clearly documenting the medical
rationale for not following specialist’s recommendations and should implement
necessary remedial measures.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care administrative processes.
Our inspectors examined the timeliness of the medical grievance process and checked
whether the institution followed reporting requirements for adverse or sentinel events and
patient deaths. Inspectors checked whether the Emergency Medical Response Review
Committee (EMRRC) met and reviewed incident packages. We investigated and determined
whether the institution conducted required emergency response drills. Inspectors also
assessed whether the Quality Management Committee (QMC) met regularly and addressed
program performance adequately. In addition, our inspectors determined whether the
institution provided training and job performance 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. Case review does not rate
this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining the
institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (74.3%)
CTF’s performance was mixed in this indicator. While CTF scored excellently in many
applicable tests, it needed improvement in multiple areas. The EMRRC either only
occasionally completed the required checklists or did not timely complete reviews. In
addition, staff conducted medical emergency response drills with incomplete documentation
or missing required emergency response drill forms. Lastly, the nurse educator did not
ensure all newly hired nurses received the required onboarding training. These findings are
set forth in the table on the next page. Based on the overall compliance score result, the OIG
rated this indicator inadequate.
Compliance Testing Results
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 Mortality Case Review reporting data. Eight patient deaths occurred
during our review period. We found no evidence in the submitted documentation the
preliminary mortality reports had been completed. These reports were overdue at the time
of OIG’s inspection (MIT 15.998).
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Compliance Score Results
Table 19. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the This is a nonscored test. Please refer to the
institution meet RCA reporting requirements? (15.001) discussion in this indicator.
Did the institution’s Quality Management Committee (QMC) meet monthly?
6 0 0 100%
(15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
3 9 0 25.0%
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 operating N/A N/A N/A N/A
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 custody staff 0 3 0 0
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
7 1 0 87.5%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
9 1 0 90.0%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
8 1 0 88.9%
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 13 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 6 0 1 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 1 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
0 1 0 0
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG medical This is a nonscored test. Please refer to Table 3
inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 74.3%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to review
CCHCS policies and procedures, relevant court orders, and guidance developed by the
American Correctional Association. We also reviewed professional literature on correctional
medical care; reviewed standardized performance measures used by the health care
industry; consulted with clinical experts; and met with stakeholders from the court, the
receiver’s office, the department, the Office of the Attorney General, and the Prison Law
Office to discuss the nature and scope of our inspection program. With input from these
stakeholders, the OIG developed a medical inspection program that evaluates the delivery of
medical care by combining clinical case reviews of patient files, objective tests of compliance
with policies and procedures, and an analysis of outcomes for certain population-based
metrics.
We rate each of the quality indicators applicable to the institution under inspection based on
case reviews conducted by our clinicians or compliance tests conducted by our registered
nurses. Figure A–1 below depicts the intersection of case review and compliance.
Figure A–1. Inspection Indicator Review Distribution for 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 7 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
The OIG medical inspection unit individually examines all the case review and compliance
inspection findings under each specific methodology. We analyze the case review and
compliance testing results for each indicator and determine separate overall indicator
ratings. After considering all the findings of each of the relevant indicators, our medical
inspectors individually determine the institution’s overall case review and compliance
ratings.
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Appendix B: Case Review Data
Table B–1. CTF Case Review Sample Sets
Sample Set Total
CTC/OHU 2
Death Review/Sentinel Events 2
Diabetes 5
Emergency Services – CPR 5
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 9
Specialty Services 3
42
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Table B–2. CTF Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 1
Anticoagulation 4
Arthritis/Degenerative Joint Disease 12
Asthma 4
Cancer 2
Cardiovascular Disease 6
Chronic Kidney Disease 3
Chronic Pain 10
Cirrhosis/End-Stage Liver Disease 5
Coccidioidomycosis 1
COPD 4
Deep Venous Thrombosis/Pulmonary Embolism 2
Diabetes 16
Gastroesophageal Reflux Disease 7
Hepatitis C 14
Hyperlipidemia 23
Hypertension 18
Mental Health 22
Migraine Headaches 1
Seizure Disorder 2
Sleep Apnea 5
Substance Abuse 9
Thyroid Disease 1
172
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Table B–3. CTF Case Review Events by Program
Diagnosis Total
Diagnostic Services 126
Emergency Care 98
Hospitalization 34
Intra-System Transfers In 10
Intra-System Transfers Out 9
Outpatient Care 364
Specialized Medical Housing 89
Specialty Services 119
849
Table B–4. CTF Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 20
MD Reviews Focused 2
RN Reviews Detailed 16
RN Reviews Focused 18
Total Reviews 56
Total Unique Cases 42
Overlapping Reviews (MD & RN) 14
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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 one
Patients condition per patient — any risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 30 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 25 OIG Q: 4.005 • See Health Information Management
Community (Medical Records) (returns from
Hospital 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, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 0 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology-related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 30 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 25 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 25 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 10 OIG inspector • Identify and inspect all on-site clinical
MITs 5.107 – 111 on-site review areas
Transfers
MITs 6.001 – 003 Intrasystem Transfers 25 SOMS • Arrival date (3 – 9 months)
• Arrived from (another departmental
facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 2 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 • See Access to Care
Medication • At least one condition per patient —
any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of IPs tested in
MIT 7.001
MIT 7.003 Returns From 25 OIG Q: 4.005 • See Health Information Management
Community Hospital (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 & med
Areas by test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site clinical
Preparation and by test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 25 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit 10 On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications medication listing 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 25 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 to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever N/A at this Cocci transfer • Reports from past 2 – 8 months
institution status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 007 RC 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 – 003 Specialized Health 10 CADDIS • Admit date (2 – 8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
• Rx count
• Randomize
MITs 13.101 – 102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care / addiction
medication, narcotic treatment
program, and transgender 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, radiology,
follow-up wound care/addiction
medication, narcotic treatment
program, and transgender services
• Randomize
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Quality No. of
Indicator Sample
Sample Category s Data Source Filters
Specialty Services (continued)
MITs 14.007 – Routine-Priority 15 Specialty Services • Approval date (3 – 9 months)
009 Initial and Follow- Appointments • Remove consult to audiology,
Up chemotherapy, dietary, Hep C, HIV,
RFS orthotics, gynecology, consult to
public health/Specialty RN,
dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry,
radiology, follow-up wound
care/addiction medication,
narcotic treatment program, and
transgender services
• Randomize
MIT 14.010 Specialty Services 20 Specialty Services • Arrived from (other
Arrivals Arrivals departmental institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – Denials 20 InterQual • Review date (3 – 9 months)
012 • Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events events report (2 – 8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 12 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB N/A at this LGB meeting • Quarterly meeting minutes
institution minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation
for ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/close (6 months)
d grievance files
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Cycle 7, Correctional Training Facility | 107
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations (continued)
MIT 15.103 Death Reports 8 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 9 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 13 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site certification • All staff
Response tracking logs • Providers (ACLS)
Certifications • 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
MIT 15.109 Pharmacy and All On-site listing of • All DEA registrations
Providers’ Drug 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 CCHCS Mortality 8 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
Cycle 7, Correctional Training Facility | 108
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Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
Cycle 7, Correctional Training Facility | 109
California Correctional Health Care Services’
Response
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
Cycle 7, Correctional Training Facility | 110
Office of the Inspector General, State of California Inspection Period: June 2023 – November 2023 Report Issued: May 2025
Cycle 7
Medical Inspection Report
for
Correctional Training Facility
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Shaun Spillane
Chief Deputy Inspector General
STATE of CALIFORNIA
May 2025
OIG