OIG
High Desert State Prison Medical Inspection Report Cycle 5
Read the report at CDCR ↗
Roy W. Wesley Office of the Inspector General
Inspector General
High Desert State Prison
Medical Inspection Results
Cycle 5
April 2018
Medical Inspection Unit Page 1
Office of the Inspector General State of California
Office of the Inspector General
HIGH DESERT STATE PRISON
Medical Inspection Results
Cycle 5
Roy W. Wesley
Inspector General
Bryan B. Beyer
Chief Deputy Inspector General
Shaun R. Spillane
Public Information Officer
April 2018
T C
ABLE OF ONTENTS
Foreword ........................................................................................................................................ i
Overall Rating: Adequate ........................................................................................................... iii
Executive Summary ...................................................................................................................... iii
Clinical Case Review and OIG Clinician Inspection Results .............................................. v
Compliance Testing Results ............................................................................................. vi
Recommendations ........................................................................................................... vii
Population-Based Metrics ................................................................................................ vii
Introduction ................................................................................................................................... 1
About the Institution ................................................................................................................... 1
Objectives, Scope, and Methodology.............................................................................................. 4
Case Reviews ............................................................................................................................. 5
Patient Selection for Retrospective Case Reviews .............................................................. 6
Benefits and Limitations of Targeted Subpopulation Review ............................................. 7
Case Review Sampling Methodology ................................................................................ 7
Breadth of Case Reviews ................................................................................................... 8
Case Review Testing Methodology.................................................................................... 9
Compliance Testing .................................................................................................................. 12
Sampling Methods for Conducting Compliance Testing................................................... 12
Scoring of Compliance Testing Results............................................................................ 12
Overall Quality Indicator Rating for Case Reviews and Compliance Testing ............................. 12
Population-Based Metrics ......................................................................................................... 13
Medical Inspection Results .......................................................................................................... 14
Access to Care ............................................................................................................ 16
Case Review Results ....................................................................................................... 16
Compliance Testing Results ............................................................................................ 19
Diagnostic Services .................................................................................................... 22
Case Review Results ....................................................................................................... 22
Compliance Testing Results ............................................................................................ 23
Emergency Services .................................................................................................... 25
Case Review Results ....................................................................................................... 25
Health Information Management ................................................................................ 27
Case Review Results ....................................................................................................... 27
Compliance Testing Results ............................................................................................ 29
Health Care Environment ........................................................................................... 30
Compliance Testing Results ............................................................................................ 30
Inter- and Intra-System Transfers ............................................................................... 33
Case Review Results ....................................................................................................... 33
Compliance Testing Results ............................................................................................ 35
Pharmacy and Medication Management ..................................................................... 36
Case Review Results ....................................................................................................... 36
Compliance Testing Results ............................................................................................ 38
High Desert State Prison, Cycle 5 Medical Inspection Table of Contents
Office of the Inspector General State of California
Prenatal and Post-Delivery Services ........................................................................... 41
Preventive Services ..................................................................................................... 42
Compliance Testing Results ............................................................................................ 42
Quality of Nursing Performance................................................................................ 44
Case Review Results ....................................................................................................... 44
Quality of Provider Performance .............................................................................. 48
Case Review Results ....................................................................................................... 48
Reception Center Arrivals ......................................................................................... 52
Specialized Medical Housing .................................................................................... 53
Case Review Results ....................................................................................................... 53
Compliance Testing Results ............................................................................................ 54
Specialty Services ..................................................................................................... 55
Case Review Results ....................................................................................................... 55
Compliance Testing Results ............................................................................................ 57
Administrative Operations (Secondary) ..................................................................... 59
Compliance Testing Results ............................................................................................ 59
Recommendations ........................................................................................................................ 62
Population-Based Metrics ............................................................................................................ 63
Appendix A — Compliance Test Results ..................................................................................... 66
Appendix B — Clinical Data ....................................................................................................... 79
Appendix C — Compliance Sampling Methodology .................................................................... 83
California Correctional Health Care Services’ Response .............................................................. 90
High Desert State Prison, Cycle 5 Medical Inspection Table of Contents
Office of the Inspector General State of California
L T F
IST OF ABLES AND IGURES
HDSP Executive Summary Table .................................................................................................. iv
HDSP Health Care Staffing Resources as of August 2017 ............................................................... 2
HDSP Master Registry Data as of August 7, 2017 .......................................................................... 3
Exhibit 1. Case Review Definitions ................................................................................................ 5
Chart 1. Case Review Sample Selection .......................................................................................... 8
Chart 2. Case Review Testing and Deficiencies ............................................................................ 10
Chart 3. Inspection Indicator Review Distribution ......................................................................... 14
Table B-1: HDSP Sample Sets ...................................................................................................... 79
Table B-2: HDSP Chronic Care Diagnoses ................................................................................... 80
Table B-3: HDSP Event – Program............................................................................................... 81
Table B-4: HDSP Review Sample Summary................................................................................. 82
High Desert State Prison, Cycle 5 Medical Inspection List of Tables and Figures
Office of the Inspector General State of California
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High Desert State Prison, Cycle 5 Medical Inspection
Office of the Inspector General State of California
F
OREWORD
Pursuant to California Penal Code Section 6126 et seq., which assigns the Office of the Inspector
General (OIG) responsibility for oversight of the California Department of Corrections and
Rehabilitation (CDCR), the OIG conducts a comprehensive inspection program to evaluate the
delivery of medical care at each of CDCR’s 35 adult prisons. The OIG explicitly makes no
determination regarding the constitutionality of care in the prison setting. That determination is
left to the Receiver and the federal court. The assessment of care by the OIG is just one factor in
the court’s determination whether care in the prisons meets constitutional standards.
The OIG’s inspections are mandated by the Penal Code and not aimed at specifically resolving
the court’s questions on constitutional care. To the degree that they provide another factor for the
court to consider, the OIG is pleased to provide added value to the taxpayers of California.
In Cycle 5, for the first time, the OIG will be inspecting institutions delegated back to CDCR
from the Receivership. There is no difference in the standards used for assessment of a delegated
institution versus an institution not yet delegated. At the time of the Cycle 5 inspection of High
Desert State Prison, the Receiver had not delegated this institution back to CDCR.
This fifth cycle of inspections will continue evaluating the areas addressed in Cycle 4, which
included clinical case review, compliance testing, and a population-based metric comparison of
selected Healthcare Effectiveness Data Information Set (HEDIS) measures. In agreement with
stakeholders, the OIG made changes to both the case review and compliance components. The
OIG found that in every inspection in Cycle 4, larger samples were taken than were needed to
assess the adequacy of medical care provided. As a result, the OIG reduced the number of case
reviews and sample sizes for compliance testing. Also, in Cycle 4, compliance testing included
two secondary (administrative) indicators (Internal Monitoring, Quality Improvement, and
Administrative Operations; and Job Performance, Training, Licensing, and Certifications). For
Cycle 5, these have been combined into one secondary indicator, Administrative Operations.
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Office of the Inspector General State of California
E S
XECUTIVE UMMARY
The OIG performed its Cycle 5 medical inspection at High Desert
State Prison (HDSP) from August to October of 2017. The
inspection included in-depth reviews of 47 patient files conducted OVERALL RATING:
by clinicians, as well as reviews of documents from 376 patient
files, covering 87 objectively scored tests of compliance with Adequate
policies and procedures applicable to the delivery of medical care.
The OIG assessed the case review and compliance results at HDSP
using 13 health care quality indicators applicable to the institution.
To conduct clinical case reviews, the OIG employs a clinician team consisting of a physician and
a registered nurse consultant, while compliance testing is done by a team of registered nurses
trained in monitoring medical policy compliance. Of the applicable indicators, seven were rated
by both case review clinicians and compliance inspectors, three were rated by case review
clinicians only, and three were rated by compliance inspectors only. The HDSP Executive
Summary Table on the following page identifies the applicable individual indicators and scores
for this institution. The OIG experts made a considered and measured overall opinion that the
quality of health care at HDSP was adequate.
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Office of the Inspector General State of California
HDSP Executive Summary Table
Cycle 5 Cycle 4
Case Review Compliance
Inspection Indicators Overall Overall
Rating Rating
Rating Rating
1—Access to Care Inadequate Adequate Inadequate Adequate
2—Diagnostic Services Adequate Inadequate Adequate Inadequate
3—Emergency Services Adequate Not Applicable Adequate Proficient
4—Health Information
Adequate Inadequate Adequate Inadequate
Management
5—Health Care Environment Not Applicable Adequate Adequate Inadequate
6—Inter- and Intra-System
Adequate Inadequate Adequate Adequate
Transfers
7—Pharmacy and Medication I
Inadequate Inadequate Inadequate n Inadequate
Management
a
8—Prenatal and Post-Delivery
Not Applicable Not Applicable Not Applicable Not Applicable
Services
9—Preventive Services Not Applicable Adequate Adequate Inadequate
10—Quality of Nursing
Adequate Not Applicable Adequate Adequate
Performance
11—Quality of Provider
Adequate Not Applicable Adequate Adequate
Performance
12—Reception Center Arrivals Not Applicable Not Applicable Not Applicable Not Applicable
13—Specialized Medical Housing Adequate Adequate Adequate Adequate
14—Specialty Services Adequate Inadequate Adequate Adequate
15—Administrative Operations
Not Applicable Inadequate Inadequate Inadequate*
(Secondary)
*In Cycle 4, there were two secondary (administrative) indicators. This score reflects the average of those
two scores.
High Desert State Prison, Cycle 5 Medical Inspection Page iv
Office of the Inspector General State of California
Clinical Case Review and OIG Clinician Inspection Results
The clinicians’ case reviews sampled patients with high medical needs and included a review of
746 patient care events.1 As depicted on the summary table on page iv, of the 13 indicators
applicable to HDSP, 10 were evaluated by clinician case review; 8 were adequate, and 2 were
inadequate. When determining the overall adequacy of care, the OIG paid particular attention to
the clinical nursing and provider quality indicators, as adequate health care staff can sometimes
overcome suboptimal compliance or performance with processes and programs. However, the
opposite is not true; inadequate health care staff cannot provide adequate care, even though the
established processes and programs onsite may be adequate. The OIG clinicians identify
inadequate medical care based on the risk of significant harm to the patient, not the actual
outcome.
Program Strengths — Clinical
• Nursing leadership at HDSP remained supportive and actively engaged in quality
improvement projects and training for the institution’s nurses.
• Provider performance in emergency settings was good. Providers made appropriate
decisions when deciding whether to send patients to an outside hospital or to treat them in
the TTA.
Program Weaknesses — Clinical
• In the area of Access to Care, service was poor due to chronic provider understaffing as well
as reduced productivity resulting from transitioning to the new electronic health record
system (EHRS). HDSP’s geographically remote location and its relatively lower
compensation rate, compared with other CDCR institutions, contributed to the institution’s
inability to recruit and retain providers.
• Medication management was poor with breaks occurring in chronic care medication
continuity. Providers documented patient health records inconsistently, making it unclear
whether patients had received their medications. Frequently, nurses put in refill requests for
medications without checking storage areas, resulting in stockrooms full of excess
medications.
• Providers often did not communicate diagnostic results to patients, as they did not
consistently generate the required patient notifications. When providers did notify patients
of their results, that communication was frequently ambiguous.
1 Each OIG clinician team consists of a board-certified physician and a registered nurse consultant with experience in
correctional and community medical settings.
High Desert State Prison, Cycle 5 Medical Inspection Page v
Office of the Inspector General State of California
Compliance Testing Results
Of the 13 health care indicators applicable to HDSP, 10 were evaluated by compliance
inspectors.2 Of these, four were adequate, and six were inadequate. There were 87 individual
compliance questions within those ten indicators, generating 1,068 data points that tested
HDSP’s compliance with California Correctional Health Care Services (CCHCS) policies and
procedures.3 Those 87 questions are detailed in Appendix A — Compliance Test Results.
Program Strengths — Compliance
The following are some of HDSP’s strengths based on its compliance scores on individual
questions in all the health care indicators:
• HDSP nursing staff received and reviewed Health Care Services Request forms that patients
submitted within required time frames, and nursing staff completed timely face-to-face
encounters with patients. HDSP nursing staff ensured that initial health assessments were
timely performed for patients admitted to the CTC, and providers timely completed their
history and physical examinations for those same patients. Clinics at HDSP were
appropriately clean, disinfected, and sanitary; clinic restrooms had operating sinks and
sufficient hygiene supplies available; and clinic staff followed proper protocols to mitigate
exposure to blood-borne pathogens and contaminated waste.
• The institution properly monitored patients for tuberculosis annually; HDSP staff offered
patients their influenza immunizations during the previous 12-month period; and patients
who met the criteria for colorectal cancer screening received the service timely.
Program Weaknesses — Compliance
The following are some of the weaknesses identified by HDSP’s compliance scores on
individual questions in all the health care indicators:
• HDSP providers did not communicate diagnostic services’ results to patients within required
time frames.
• The institution did not timely scan non-dictated documents and specialty services’ reports
into patients’ electronic medical records. In addition, OIG inspectors found missing initials
and dates on some reports, indicating providers had not always reviewed hospital discharge
reports.
2 The OIG’s compliance team consists of inspectors who are registered nurses with expertise in CDCR policies
regarding medical staff and processes.
3 The OIG used its own clinicians to provide clinical expert guidance for testing compliance in certain areas for which
CCHCS policies and procedures did not specifically address an issue.
High Desert State Prison, Cycle 5 Medical Inspection Page vi
Office of the Inspector General State of California
• At HDSP, providers did not always review high priority specialty service reports within
required time frames.
Recommendations
The OIG recommends the following:
• The HDSP chief physician and surgeon (CP&S) or chief medical executive (CME) should
periodically check the electronic health record system (EHRS) message center to ensure
providers promptly review all pertinent results and reports.
• HDSP should designate an onsite physician supervisor who can support mid-level providers,
review their work, and provide appropriate supervision.
• At the time of the OIG’s onsite inspection, HDSP unnecessarily delayed transmitting
telemedicine specialty recommendations. The institution should send telemedicine specialty
recommendations to the provider immediately, as it already does for offsite specialty
recommendations. By using similar rapid processes for transmitting both types of specialty
recommendations, HDSP can reduce the risk of lapses in care.
Population-Based Metrics
In general, HDSP performed well as measured by population-based metrics. In comprehensive
diabetes care, HDSP outperformed most state and national health care plans in the five diabetic
measures. However, HDSP scored lower than two health care plans for diabetic eye exams and
blood pressure control.
With regard to immunization measures, HDSP scored higher than all other health care plans for
influenza immunizations for both younger and older adults. However, the institution’s score for
pneumococcal immunizations was mixed, matching the score for one health care plan, but
scoring significantly lower than one other health care plan. Colorectal cancer screening scores
were mixed, with the institution scoring higher than two health plans, matching the score of one
health plan, and scoring lower than two other health plans.
HDSP performed well as measured by population-based metrics compared to the other health
care plans reviewed. The institution may improve its scores for colorectal cancer screenings
by reducing patient refusals through educating patients on the benefits of these preventive
services.
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Office of the Inspector General State of California
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Office of the Inspector General State of California
I
NTRODUCTION
Pursuant to California Penal Code Section 6126 et seq., which assigns the Office of the Inspector
General (OIG) responsibility for oversight of the California Department of Corrections and
Rehabilitation (CDCR), and at the request of the federal Receiver, the OIG developed a
comprehensive medical inspection program to evaluate the delivery of medical care at each of
CDCR’s 35 adult prisons. The OIG conducted a clinical case review and a compliance
inspection, ensuring a thorough, end-to-end assessment of medical care within CDCR.
High Desert State Prison (HDSP) was the 23rd medical inspection of Cycle 5. During the
inspection process, the OIG assessed the delivery of medical care to patients using the primary
clinical health care indicators applicable to the institution. The Administrative Operations
indicator is secondary because it does not reflect the actual clinical care provided.
ABOUT THE INSTITUTION
Opened in 1995, High Desert State Prison (HDSP) is located approximately eight miles east of
the town of Susanville, in Lassen County. The institution’s primary mission is to provide housing
and programming of general population and sensitive needs high-security (Level IV) and
sensitive needs medium-security (Level III) patients.
The institution operates several medical clinics where health care staff members handle routine
requests for medical services. In addition, HDSP operates a triage and treatment area (TTA) for
urgent and emergent patient care, a receiving and release (R&R) clinic for assessment of arriving
and departing patients, and a specialty clinic. The institution also provides inpatient health care
in its correctional treatment center (CTC) for those patients who require a higher level of service.
CCHCS has designated HDSP as a “basic” health care institution, an institution located in a rural
area away from tertiary care centers and specialty care providers whose services would likely be
used frequently by higher-risk patients. Because of HDSP’s remote location and its basic health
care status, CDCR houses healthier patients at this institution.
The institution first received national accreditation from the Commission on Accreditation for
Corrections in August 2013. This accreditation program is a professional peer review process
based on national standards set by the American Correctional Association. HDSP was
re-accredited on August 7, 2016.
Based on staffing data the OIG obtained from the institution as identified in the HDSP Health
Care Staffing Resources as of August 2017 table below, HDSP’s vacancy rate among medical
managers, primary care providers, supervisors, and rank-and-file nurses was 25 percent in
August 2017, with the highest vacancy percentage among management at 54 percent. At the time
of the OIG’s inspection, HDSP had been experiencing challenges in the area of medical
leadership. In April 2017, HDSP’s chief medical executive (CME) passed away. From
April 2017 until July 2017, a chief physician and surgeon (CP&S) from a different facility
High Desert State Prison, Cycle 5 Medical Inspection Page 1
Office of the Inspector General State of California
provided temporary, out-of-classification CME coverage. Since July 2017, the CME position at
HDSP remained vacant. The HDSP CP&S position was completely vacant during the OIG’s
inspection period. As of this report, the institution was in the process of filling that position.
HDSP Health Care Staffing Resources as of August 2017
Primary Care Nursing
Management Nursing Staff Totals
Providers Supervisors
Description Number % Number % Number % Number % Number %
Authorized
13 8% 42.5 25% 9.7 6% 104.2 62% 169.4 100%
Positions
Filled
6 46% 30 71% 8 82% 83 80% 127 75%
Positions
Vacancies 7 54% 12.5 29% 1.7 18% 21.2 20% 42.4 25%
Recent Hires
(within 12 2 33% 6 20% 0 0% 26 31% 34 27%
months)
Staff Utilized
0 0% 0 0% 0 0% 8 10% 8 6%
from Registry
Redirected
Staff 0 0% 0 0% 0 0% 0 0% 0 0%
(to
NStoanff- Pona tient
CLoanrge -Aterremas ) 0 0% 0 0% 0 0% 2 2% 2 2%
Medical
L eave
Note: HDSP Health Care Staffing Resources data was not validated by the OIG.
As of August 7, 2017, the Master Registry for HDSP showed that the institution had a total
population of 3,573. Within that total population, 0.6 percent was designated as high medical
risk, Priority 1 (High 1), and 2.0 percent was designated as high medical risk, Priority 2 (High 2).
Patients’ assigned risk levels are based on the complexity of their required medical care related
to their specific diagnoses, frequency of higher levels of care, age, and abnormal laboratory
results and procedures. High 1 has at least two high-risk conditions; High 2 has only one.
Patients at high medical risk are more susceptible to poor health outcomes than those at medium
or low medical risk. Patients at high medical risk also typically require more health care services
than do patients with lower assigned risk levels. The chart below illustrates the breakdown of the
institution’s medical risk levels at the start of the OIG medical inspection.
High Desert State Prison, Cycle 5 Medical Inspection Page 2
Office of the Inspector General State of California
HDSP Master Registry Data as of August 7, 2017
Medical Risk Level Number of Patients Percentage
High 1 20 0.6%
High 2 73 2.0%
Medium 1,498 41.9%
Low 1,982 55.5%
Total 3,573 100%
High Desert State Prison, Cycle 5 Medical Inspection Page 3
Office of the Inspector General State of California
O , S , M
BJECTIVES COPE AND ETHODOLOGY
In designing the medical inspection program, the OIG reviewed CCHCS policies and procedures,
relevant court orders, and guidance developed by the American Correctional Association. The
OIG also reviewed professional literature on correctional medical care; reviewed standardized
performance measures used by the health care industry; consulted with clinical experts; and met
with stakeholders from the court, the Receiver’s office, CDCR, the Office of the Attorney
General, and the Prison Law Office to discuss the nature and scope of the OIG’s inspection
program. With input from these stakeholders, the OIG developed a medical inspection program
that evaluates medical care delivery by combining clinical case reviews of patient files, objective
tests of compliance with policies and procedures, and an analysis of outcomes for certain
population-based metrics.
To maintain a metric-oriented inspection program that evaluates medical care delivery
consistently at each state prison, the OIG identified 15 indicators (14 primary (clinical) indicators
and one secondary (administrative) indicator) of health care to measure. The primary quality
indicators cover clinical categories directly relating to the health care provided to patients,
whereas the secondary quality indicator addresses the administrative functions that support a
health care delivery system. The HDSP Executive Summary Table on page iv of this report
identifies these 15 indicators.
The OIG rates each of the quality indicators applicable to the institution under inspection based
on case reviews conducted by OIG clinicians and compliance tests conducted by OIG registered
nurses. The case review results alone, the compliance test results alone, or a combination of both
these information sources may influence an indicator’s overall rating. For example, the OIG
derives the ratings for the primary quality indicators Quality of Nursing Performance and
Quality of Provider Performance entirely from the case review done by clinicians, while the
ratings for the primary quality indicators Health Care Environment and Preventive Services are
derived entirely from compliance testing done by registered nurse inspectors. As another
example, primary quality indicators such as Diagnostic Services and Specialty Services receive
ratings derived from both sources.
The OIG does not inspect for efficiency or cost-effectiveness of medical operations. Consistent
with the OIG’s agreement with the Receiver, this report only addresses the quality of CDCR’s
medical operations and its compliance with quality-related policies. Moreover, if the OIG learns
of a patient needing immediate care, the OIG notifies the chief executive officer of health care
services and requests a status report. Additionally, if the OIG learns of significant departures
from community standards, it may report such departures to the institution’s chief executive
officer or to CCHCS. Because these matters involve confidential medical information protected
by state and federal privacy laws, the OIG does not include specific identifying details related to
any such cases in the public report.
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Office of the Inspector General State of California
In all areas, the OIG is alert for opportunities to make appropriate recommendations for
improvement. Such opportunities may be present regardless of the score awarded to any
particular quality indicator; therefore, recommendations for improvement are not necessarily
indicative of deficient medical care delivery.
CASE REVIEWS
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of its
stakeholders, which continues in the Cycle 5 medical inspections. The following exhibit provides
definitions that describe this process.
Exhibit 1. Case Review Definitions
Case = Sample = Patient
An appraisal of the medical care provided to one patient over a specific
period, which can comprise detailed or focused case reviews.
Detailed Case Review
A review that includes all aspects of one patient’s medical care assessed over
a six-month period. This review allows the OIG clinicians to examine many
areas of health care delivery, such as access to care, diagnostic services,
health information management, and specialty services.
Focused Case Review
A review that focuses on one specific aspect of medical care. This review
tends to concentrate on a singular facet of patient care, such as the sick call
process or the institution’s emergency medical response.
Case Review Event
A direct or indirect interaction between the patient and the health care system.
Examples of direct interactions include provider encounters and nurse
encounters. An example of an indirect interaction includes a provider
reviewing a diagnostic test and placing additional orders.
Case Review Deficiency
A medical error in procedure or in clinical judgment. Both procedural and
clinical judgment errors can result in policy non-compliance, elevated risk of
patient harm, or both.
Adverse Deficiency
A medical error that increases the risk of, or results in, serious patient harm.
Most health care organizations refer to these errors as adverse events.
High Desert State Prison, Cycle 5 Medical Inspection Page 5
Office of the Inspector General State of California
The OIG’s clinicians perform a retrospective case review of selected patient files to evaluate the
care given by an institution’s primary care providers and nurses. Retrospective case review is a
well-established review process used by health care organizations that perform peer reviews and
patient death reviews. Currently, CCHCS uses retrospective case review as part of its death
review process and in its pattern-of-practice reviews. CCHCS also uses a more limited form of
retrospective case review when performing appraisals of individual primary care providers.
Patient Selection for Retrospective Case Reviews
Because retrospective case review is time consuming and requires qualified health care
professionals to perform it, the OIG must carefully select a sample of patient records for clinician
review. Accordingly, the group of patients the OIG targeted for case review carried the highest
clinical risk and utilized the majority of medical services. The majority of patients selected for
retrospective case review were high-utilizing patients with chronic care illnesses who were
classified as high or medium risk. The reason the OIG targeted these patients for review is
twofold:
1. The goal of retrospective case review is to evaluate all aspects of the health care system.
Statewide, high-risk and high-utilization patients consume medical services at a
disproportionate rate; 11 percent of the total patient population is high-risk and accounts
for more than half of the institution’s pharmaceutical, specialty, community hospital, and
emergency costs.
2. Selecting this target group for case review provides a significantly greater opportunity to
evaluate all the various aspects of the health care delivery system at an institution.
Underlying the choice of high-risk patients for detailed case review, the OIG clinical experts
made the following three assumptions:
1. If the institution is able to provide adequate clinical care to the most challenging patients
with multiple complex and interdependent medical problems, it is more likely to provide
adequate care to patients with less complicated health care issues. Because clinical
expertise is required to determine whether the institution has provided adequate clinical
care, the OIG utilizes experienced correctional physicians and registered nurses to
perform this analysis.
2. The health of less complex patients is more likely to be affected by processes such as
timely appointment scheduling, medication management, routine health screening, and
immunizations. To review these processes, the OIG simultaneously performs a broad
compliance review.
3. Patient cases generated during death reviews, sentinel events (unexpected occurrences
involving death or serious injury, or risk thereof), and hospitalizations are more likely to
comprise high-risk patients.
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Office of the Inspector General State of California
Benefits and Limitations of Targeted Subpopulation Review
Because the patients selected utilize the broadest range of services offered by the health care
system, the OIG’s retrospective case review provides adequate data for a qualitative assessment
of the most vital system processes (referred to as “primary quality indicators”). Retrospective
case review provides an accurate qualitative assessment of the relevant primary quality indicators
as applied to the targeted subpopulation of high-risk and high-utilization patients. While this
targeted subpopulation does not represent the prison population as a whole, the institution’s
ability to respond with adequate medical care to this subpopulation is a crucial and vital indicator
of how the institution provides health care to its whole patient population. Simply put, if the
institution’s medical system does not respond adequately for those patients needing the most
care, then it is not fulfilling its obligations, even if it takes good care of patients with less
complex medical needs.
Since the targeted subpopulation does not represent the institution’s general prison population,
the OIG cautions against inappropriate extrapolation of medical conditions or outcomes from the
retrospective case reviews to the general population. For example, if the high-risk diabetic
patients reviewed have poorly controlled diabetes, one cannot conclude that all the diabetics’
conditions are poorly controlled. Similarly, if the high-risk diabetic patients under review have
poor outcomes, one cannot conclude that the entire diabetic population is having similarly poor
outcomes. The OIG does not extrapolate conditions or outcomes, but instead extrapolates the
institution’s response for those patients needing the most care because the response yields
valuable system information.
In the above example, if the institution responds by providing appropriate diabetic monitoring,
medication therapy, and specialty referrals for the high-risk patients reviewed, then it is
reasonable to infer that the institution is also responding appropriately to all the diabetics in the
prison. However, if these same high-risk patients needing monitoring, medications, and referrals
are not getting those needed services, it is likely that the institution is not providing appropriate
diabetic services.
Case Review Sampling Methodology
Using a pre-defined case review sampling algorithm, OIG analysts apply various filters to each
institution’s patient population. The various filters include medical risk status, number of
prescriptions, number of specialty appointments, number of clinic appointments, and other
health-related data. The OIG uses these filters to narrow down the population to those patients
with the highest utilization of medical resources (see Chart 1, next page). To prevent selection
bias, the OIG ensures that the same clinicians who perform the case reviews do not participate in
the sample selection process.
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Office of the Inspector General State of California
Chart 1. Case Review Sample Selection
Sample Selection
Analysts apply filters to the population to obtain
samples (S) with high utilization. Six permutations, Population
or arrangements, of case review types are possible
for each sample.
S S
MD RN MD RN MD RN S S
S S
D F D D F D
Case = Sample = Patient
MD RN RN
D D F
MD = Provider
RN = Registered Nurse
D = Detailed
F = Focused
The OIG’s case sample size matched those of other qualitative research. The empirical findings,
supported by expert statistical consultants, showed adequate conclusions after 10 to 15 cases had
undergone comprehensive, or detailed, clinician review. In qualitative statistics, this
phenomenon is known as “saturation.” The OIG found the Cycle 4 medical inspection sample
size of 30 for detailed physician reviews far exceeded the saturation point necessary for an
adequate qualitative review. At the end of Cycle 4 inspections, the OIG re-analyzed the case
review results using half the number of cases; there were no significant differences in the ratings.
To improve inspection efficiency while preserving the quality of the inspection, the OIG reduced
the number of the samples for Cycle 5 medical inspections to the current levels. For most basic
institutions, the OIG samples 20 cases for detailed physician review. For intermediate institutions
and several basic institutions with larger high-risk populations, the OIG samples 25 cases. For
California Health Care Facility, the OIG samples 30 cases for detailed physician review.
Breadth of Case Reviews
As indicated in Appendix B, Table B-1: HDSP Sample Sets, the OIG clinicians evaluated medical
records for 47 unique cases. Appendix B, Table B-4: HDSP Case Review Sample Summary
clarifies that both nurses and physicians reviewed medical records for 13 of those cases, for
60 reviews in total. Physicians performed detailed reviews of 20 cases, and nurses performed
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detailed reviews of 12 cases, totaling 32 detailed reviews. Nurses also performed a focused
review for an additional 27 cases, while physicians performed a focused review for one
additional case. These reviews generated 746 case review events (Appendix B, Table B-3: HDSP
Event – Program).
While the sample method specifically pulled only 6 chronic care patient records, i.e., 5 diabetes
patients and one anticoagulation patient (Appendix B, Table B-1: HDSP Sample Sets), the
47 unique patients sampled included patients with 131 chronic care diagnoses, including
8 additional patients with diabetes (for a total of 13) and zero additional anticoagulation patients
(for a total of one) (Appendix B, Table B-2: HDSP Chronic Care Diagnoses). The OIG’s sample
selection tool allowed evaluation of many chronic care programs because the complex and
high-risk patients selected from the different categories often had multiple medical problems.
While the OIG did not evaluate every chronic disease or health care staff member, the OIG did
assess for adequacy the overall operation of the institution’s system and staff.
Case Review Testing Methodology
A physician, a nurse consultant, or both clinician inspectors review each case. The OIG clinician
inspector can perform one of two different types of case review: detailed or focused (see
Exhibit 1, p. 5, and Chart 1, p. 8). As the OIG clinician inspector reviews the medical record for
each sample, the inspector records pertinent interactions between the patient and the health care
system. These interactions are also known as case review events. When an OIG clinician
inspector identifies a medical error, the inspector also records these errors as case review
deficiencies. If a deficiency is of such magnitude that it caused, or had the potential to cause,
serious patient harm, then the OIG clinician records it as an adverse deficiency (see Chart 2, next
page).
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Chart 2. Case Review Testing and Deficiencies
Case Review Testing
The OIG clinicians examine the chosen samples, performing a detailed case review
or a focused case review, to determine the events that occurred.
Sample = Patient = Case
No
Deficiency
Sample
Events
Deficiency
A sample leading to events
Deficiencies
Not all events lead to deficiencies (medical errors); however, if there are errors, then
the OIG clinicians determine whether any are adverse.
Sample Events Deficiency*
A sample leading to events
with deficiencies observed
Adverse
* If a deficiency is serious
Deficiency
enough, the OIG clinician
labels it adverse.
When the OIG clinician inspectors have reviewed all cases, they analyze the deficiencies. OIG
inspectors search for similar types of deficiencies to determine if a repeating pattern of errors
existed. When the same type of error occurs multiple times, the OIG inspectors identify those
errors as findings. When the error is frequent, the likelihood is high that the error is regularly
recurring at the institution. The OIG categorizes and summarizes these deficiencies in one or
more health care quality indicators in this report to help the institution focus on areas for
improvement.
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Additionally, the OIG physicians also rate each of the detailed physician cases for adequacy
based on whether the institution met the patient’s medical needs and if it placed the patient at
significant risk of harm. The cumulative analysis of these cases gives the OIG clinicians
additional perspective to help determine whether the institution is providing adequate medical
services or not.4
Based on the collective results of clinicians’ case reviews, the OIG clinicians rated each quality
indicator proficient (excellent), adequate (passing), or inadequate (failing). A separate
confidential HDSP Supplemental Medical Inspection Results: Individual Case Review
Summaries report details the case reviews the OIG clinicians conducted and is available to
specific stakeholders. For further details regarding the sampling methodologies and counts, see
Appendix B — Clinical Data, Table B-1; Table B-2; Table B-3; and Table B-4.
4 Regarding individual provider performance, the OIG did not design the medical inspection to be a focused search for
poorly performing providers; rather, the inspection assesses each institution’s systemic health care processes.
Nonetheless, while the OIG does not purposefully sample cases to review each provider at the institution, the cases
usually involve most of the institutions’ providers. Providers should only escape OIG case review if institutional
managers assigned poorly performing providers the care of low-utilizing and low-risk patients, or if the institution had a
relatively high number of providers.
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COMPLIANCE TESTING
Sampling Methods for Conducting Compliance Testing
From August to October 2017, registered nurse inspectors obtained answers to 87 objective
medical inspection test (MIT) questions designed to assess the institution’s compliance with
critical policies and procedures applicable to the delivery of medical care. To conduct most tests,
inspectors randomly selected samples of patients for whom the testing objectives were applicable
and reviewed their electronic medical records. In some cases, inspectors used the same samples
to conduct more than one test. In total, inspectors reviewed health records for 376 individual
patients and analyzed specific transactions within their records for evidence that critical events
occurred. Inspectors also reviewed management reports and meeting minutes to assess certain
administrative operations. In addition, during the week of August 21, 2017, registered nurse field
inspectors conducted a detailed onsite inspection of HDSP’s medical facilities and clinics;
interviewed key institutional employees; and reviewed employee records, logs, medical appeals,
death reports, and other documents. This generated 1,057 scored data points to assess care.
In addition to the scored questions, the OIG obtained information from the institution that it did
not score. This included, for example, information about HDSP’s plant infrastructure, protocols
for tracking medical appeals and local operating procedures, and staffing resources.
For details of the compliance results, see Appendix A — Compliance Test Results. For details of
the OIG’s compliance sampling methodology, see Appendix C — Compliance Sampling
Methodology.
Scoring of Compliance Testing Results
After compiling the answers to the 87 questions for the ten indicators for which compliance
testing was applicable, the OIG compliance team derived a score for each quality indicator by
calculating the percentage score of all Yes answers for each of the questions applicable to a
particular indicator, then averaging those scores. Based on those results, the OIG assigned a
rating to each quality indicator of proficient (greater than 85 percent), adequate (between
75 percent and 85 percent), or inadequate (less than 75 percent).
OVERALL QUALITY INDICATOR RATING FOR CASE REVIEWS AND COMPLIANCE
TESTING
The OIG derived the final rating for each quality indicator by combining the ratings from the
case reviews and from the compliance testing, as applicable. When combining these ratings, the
case review evaluations and the compliance testing results usually agreed, but there were
instances for this inspection when the rating differed for a particular quality indicator. In those
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instances, the inspection team assessed the quality indicator based on the collective ratings from
both components. Specifically, the OIG clinicians and registered nurse inspectors discussed the
nature of individual exceptions found within that indicator category and considered the overall
effect on the ability of patients to receive adequate medical care.
To derive an overall assessment rating of the institution’s medical inspection, the OIG evaluated
the various rating categories assigned to each of the quality indicators applicable to the
institution, giving more weight to the rating results of the primary quality indicators, which
directly relate to the health care provided to patients. Based on that analysis, OIG experts made a
considered and measured overall opinion about the quality of health care observed.
POPULATION-BASED METRICS
The OIG identified a subset of Healthcare Effectiveness Data Information Set (HEDIS) measures
applicable to the CDCR patient population. To identify outcomes for HDSP, the OIG reviewed
some of the compliance testing results, randomly sampled additional patients’ records, and
obtained HDSP data from the CCHCS Master Registry. The OIG compared those results to
HEDIS metrics reported by other statewide and national health care organizations.
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M I R
EDICAL NSPECTION ESULTS
The OIG’s case review and clinician teams use quality indicators to assess the clinical aspects of
health care. The HDSP Executive Summary Table on page iv of this report identifies the
13 indicators applicable to this institution. The following chart depicts their union and
intersection:
Chart 3. Inspection Indicator Review Distribution
Case Review Compliance
1 — Access to Care
2 — Diagnostic Services
3 — Emergency
5 — Health Care
Services 4 — Health Information
Environment
Management
10 — Quality of
Nursing 6 — Inter- and Intra-System 9 — Preventive
Performance Transfers Services
11 — Quality of 7 — Pharmacy and Medication 15 — Administrative
Provider Management Operations
Performance
13 — Specialized Medical Housing
14 — Specialty Services
The Administrative Operations indicator is a secondary indicator; therefore, the OIG did not rely
upon this indicator when determining the institution’s overall score. Based on the analysis and
results in all the primary indicators, the OIG experts made a considered and measured opinion
that the quality of health care at HDSP was adequate.
Summary of Case Review Results: The clinical case review component assessed ten primary
(clinical) indicators applicable to HDSP. Of these ten indicators, OIG clinicians rated eight
adequate and two inadequate.
The OIG physicians rated the overall adequacy of care for each of the 20 detailed case reviews
they conducted. Of these 20 cases, one was proficient, 15 were adequate, and 4 were inadequate.
In the 746 events reviewed, there were 204 deficiencies, 76 of which were considered to be of
such magnitude that, if left unaddressed, they would likely contribute to patient harm.
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Adverse Deficiencies Identified During Case Review: Adverse deficiencies are medical errors
that markedly increased the risk of, or resulted in, serious patient harm. Medical care is a
complex and dynamic process with many moving parts, subject to human error even within the
best health care organizations. All major health care organizations typically identify and track
adverse deficiencies for the purpose of quality improvement. Adverse deficiencies are not
typically representative of medical care delivered by the organization. The OIG normally
identifies adverse deficiencies for the dual purposes of quality improvement and the illustration
of problematic patterns of practice found during the inspection. Because of the anecdotal nature
of these deficiencies, the OIG cautions against drawing inappropriate conclusions regarding the
institution based solely on adverse deficiencies. The OIG identified no adverse deficiencies in
the case reviews at HDSP.
Summary of Compliance Results: The compliance component assessed 10 of the 13 indicators
applicable to HDSP. Of these ten indicators, OIG inspectors rated four adequate and six
inadequate. The test questions used to assess compliance for each indicator are detailed in
Appendix A.
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ACCESS TO CARE
This indicator evaluates the institution’s ability to provide
Case Review Rating:
patients with timely clinical appointments. Compliance and Inadequate
case review teams review areas specific to patients’ access to Compliance Score:
care, such as initial assessments of newly arriving patients, Adequate
(75.5%)
acute and chronic care follow-ups, face-to-face nurse
appointments when patients request to be seen, provider Overall Rating:
referrals from nursing lines, and follow-ups after Inadequate
hospitalization or specialty care. Compliance testing for this
indicator also evaluates whether patients have Health Care Services Request forms (CDCR Form
7362) available in their housing units.
In this indicator, the OIG case review and compliance review processes yielded different results,
with the case reviewers assigning an inadequate rating and the compliance review resulting in an
adequate score. The poor performance in provider-ordered follow-ups, nurse-requested
follow-ups, provider appointments for patients newly admitted to the institution, and diagnostic
results’ follow-ups all significantly affected the quality of care provided. Compliance testing also
yielded poor performance in nurse-initiated follow-ups, specialty follow-ups, and hospitalization
follow-ups. The OIG’s internal review process considered those factors that led to both scores.
Given the clinical importance of the deficiencies identified, the OIG determined the overall
rating of inadequate was appropriate for this indicator.
Case Review Results
The OIG clinicians reviewed 270 provider, nurse, specialty, and hospital events that required a
follow-up appointment and identified 63 deficiencies relating to Access to Care¸ 35 of which
were significant. These deficiencies represented problems with health care access, which will be
discussed below.
Provider-to-Provider Follow-up Appointments
HDSP performed poorly with provider-ordered follow-up appointments. There were
19 deficiencies in this area, 11 of which were significant. The OIG clinicians identified
deficiencies in cases 1, 7, 8, 9, 10, 11, 13, 17, 26, 27, and 29. There were two patterns of severe
deficiencies: significant appointment delays and appointments prematurely canceled before a
provider could address issues. The following are examples of these concerns:
• In case 1, HDSP staff erroneously marked appointments “completed,” even though the
provider did not address the reason for the appointment. Those appointments were not
rescheduled. The provider also ordered a chronic care appointment for 90 days, but less than
one month later, HDSP staff again erroneously canceled the appointment and dropped the
patient’s chronic care program.
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• In case 8, the provider requested an appointment within nine days to discuss the patient’s
diabetes and his apparent reluctance to manage it. Instead, the appointment occurred 18 days
late, a significant delay.
• Also in case 8, the provider intended to follow the patient closely by ordering a three-day
follow-up appointment after adjusting diabetes medication. The provider also ordered a
30-day follow-up appointment. Both appointments were canceled inappropriately during an
attempt to bundle them to provide more efficient patient care. HDSP staff thus lost the
patient to follow up for more than four months and dropped his diabetes care.
• In case 11, HDSP bundled three appointments to address the patient’s chronic care concerns,
to discuss his cardiology consultation, and to review his medical accommodations. The
provider addressed neither the cardiology consultation nor the chronic care issues, which
meant the patient’s diabetes, heart disease, and high blood pressure concerns were all
dropped. Ultimately, this meant the institution lost track of the patient’s medical care.
RN Sick Call Access
Patients who submitted sick call requests did not always see the nurse within the required time
frame. Nurses received and reviewed sick call requests each morning. Of the 98 sick call
requests reviewed, HDSP did not provide patients with prompt access to sick call nursing
appointments in cases 10, 13, 33, and 38. Furthermore, the OIG clinicians reviewed two cases in
which the nurse did not assess a patient with urgent medical symptoms on the same day. These
cases are discussed in the Quality of Nursing Performance indicator.
RN-to-Provider Referrals
Nurses referred patients to a provider when the patient needed a higher level of care for diagnosis
and treatment. HDSP performed poorly with half of these nurse-to-provider referrals that did not
occur timely. The OIG clinicians reviewed 30 nursing encounters that generated a provider
follow-up referral and found provider appointments were delayed in cases 1, 2, 10, 13, 15, 29,
31, 32, 33, 34, and 44. In case 2, the HDSP staff did not schedule the provider appointment at all.
RN Follow-up Appointments
HDSP also had difficulty with scheduling and completing registered nurse (RN) follow-up
appointments that providers or nurses generated. The OIG clinicians reviewed 11 RN follow-up
referrals and noted RN appointments were delayed 11 days in case 9, and 4 days in case 37. Two
RN appointments did not occur at all in case 11.
Provider Follow-up After Specialty Services
HDSP performed well with ensuring provider follow-up appointments occurred after specialty
services. The OIG clinicians reviewed 61 specialty services requiring follow-up and found minor
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delays in cases 2 and 19, which did not affect the quality of the care provided. Performance in
this area is further discussed in the Specialty Services indicator.
Intra-System Transfers
As in Cycle 4, HDSP had trouble with providing timely access to provider appointments for new
patients who transferred from other CDCR institutions. Of the ten transfer-in patients reviewed,
the OIG clinicians identified delays in provider appointments ranging from two days up to three
weeks in cases 21, 22, 31, and 41.
Follow-up After Hospitalization
HDSP performed well in ensuring providers followed up with their patients after an outside
hospitalization or emergency department visit. CCHCS policy requires institutions to provide a
follow-up appointment within five days of these visits. The OIG clinicians reviewed
19 occurrences of hospitalizations and outside emergency department visits, and observed only
one significant deficiency.
Follow-up After Urgent/Emergent Care
HDSP performance was acceptable with ensuring provider follow-up for patients seen in the
TTA and who were sent back to housing. As noted above for the preceding area, CCHCS policy
requires institutions to provide a follow-up appointment within five days of such visits. The OIG
clinicians reviewed 29 TTA events and found 11 of them required a five-day follow-up
appointment. Two deficiencies were noted in this area.
Specialized Medical Housing
Provider access was good for patients admitted to the CTC. The OIG reviewed 36 CTC
admissions and encounter events. Only five instances occurred in which the providers did not
perform timely CTC rounds; all were minor deficiencies.
Specialty Access and Follow-up
The institution performed well with requesting specialist consultations and follow-up
appointments. Performance in this area is discussed further in the Specialty Services indicator.
Diagnostic Results Follow-up
HDSP provided poor follow-up care to patients after diagnostic tests returned abnormal results.
After reviewing results, providers are required to review diagnostic tests, and to request
appointments and notify the patient whether further follow-up is necessary. The OIG clinicians
noted several other minor delays, along with two significant delays as described in the following:
• In case 8, the provider reviewed an abnormal test result showing poorly controlled diabetes,
but did not request an appointment to follow up with the patient. By chance, the nurse
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reviewed the result 25 days later and ordered a 7-day provider follow-up. Unfortunately, the
appointment occurred with a 17-day delay. Ultimately, the provider saw the patient 50 days
after the abnormal blood test.
• In case 9, the patient received an abnormal test result showing poorly controlled diabetes.
The provider did not review the result. Fortunately, the nurse reviewed the result 45 days
later and requested the follow-up.
Clinician Onsite Inspection
The OIG clinicians discussed the Access to Care deficiencies with HDSP schedulers, who
explained the problem was a lack of available provider appointments. HDSP had lost one
provider to retirement, and another to medical leave with an indeterminate return date. In
addition, transitioning to the new EHRS had resulted in a severe decline in provider productivity.
To ameliorate the delays, HDSP had begun closely monitoring both scheduled and completed
appointments to improve current providers’ productivity levels. HDSP staff had bundled
appointments to increase efficiency.
Case Review Conclusion
HDSP performance was poor with regard to Access to Care. The vast majority of deficiencies
resulted from delayed provider follow-ups, with the most significant deficiencies leading to
dropped care in several cases. The chronic situation of provider understaffing and the decrease in
staff productivity experienced with the EHRS transition were obstacles that proved too difficult
for the institution to overcome. While HDSP attempted to address the backlog of appointments
by aggressively bundling them, unfortunately, this strategy failed when the provider did not
address all the bundled issues. This bundling resulted in dropped care for patients as observed in
cases 8 and 11. In both instances, HDSP lost track of these patients and failed to schedule any
follow-up appointments. The case review rating for this indicator was inadequate.
Compliance Testing Results
The institution performed in the adequate range, with a score of 75.5 percent in the Access to
Care indicator. The following tests earned scores in the proficient range:
• OIG inspectors sampled 30 health care services request forms that patients submitted across
all facility clinics. Nursing staff completed timely face-to-face triage encounters for all
30 patients (MIT 1.004).
• Patients could access health care services request forms at all six housing units the OIG
inspected (MIT 1.101).
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• OIG inspectors sampled 30 health care services request forms and found that nursing staff
reviewed the forms on the same day received for 29 of them (97 percent). For one sample,
nursing staff reviewed the services request form one day late (MIT 1.003).
Two tests received scores in the adequate range:
• When the OIG reviewed recent appointments for 25 sampled patients with chronic care
conditions, 20 patients (80 percent) received timely provider follow-up appointments. Four
patients received chronic care appointments from 11 to 93 days late. For one patient, the
appointment did not occur (MIT 1.001).
• Of the nine applicable patients sampled whom nursing staff referred to a provider and for
whom the provider subsequently ordered a follow-up appointment, seven (78 percent)
received their follow-up appointments timely. Of the remaining two patients, one received
his follow-up appointment four days late, and for the other patient, OIG inspectors found no
medical record evidence a follow-up appointment occurred (MIT 1.006).
The OIG inspectors found room for improvement in the following four tests:
• Only 17 of 26 sampled patients (65 percent) who received a high-priority or routine
specialty service also received a timely follow-up appointment with a provider. Of the nine
patients who did not receive timely follow-up appointments, six patients’ high-priority
specialty service follow-up appointments were 2 to 31 days late, and one patient did not
receive his follow-up appointment. One patient’s routine specialty service follow-up
appointment was 17 days late, and one other patient did not receive his appointment
(MIT 1.008).
• OIG inspectors tested eight patients discharged from an outside hospital to determine
whether they received a provider follow-up appointment at HDSP within five calendar days
of their return to the institution. Five patients (62 percent) received a timely provider
follow-up appointment. Two patients received their appointments one and three days late.
For the remaining patient, OIG inspectors found no medical record evidence that his
follow-up occurred (MIT 1.007).
• Among 23 health care services request forms (CDCR Form 7362) sampled on which nursing
staff referred the patient for a provider appointment, only 14 patients (61 percent) received
timely appointments. Six patients received their appointments from 4 to 38 days late. For
three other patients, OIG inspectors found no medical record evidence that the primary care
visit occurred (MIT 1.005).
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• Among 25 patients sampled who transferred into HDSP from other institutions and whom
nurses referred to a provider based on their initial health care screening, only 9 of them
(36 percent) were seen timely. Eleven patients received their provider appointments from
10 to 134 days late, but for the five remaining patients, they did not receive their
appointments (MIT 1.002).
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DIAGNOSTIC SERVICES
This indicator addresses several types of diagnostic services.
Case Review Rating:
Specifically, it addresses whether radiology and laboratory Adequate
services were timely provided to patients, whether primary Compliance Score:
care providers timely reviewed results, and whether providers Inadequate
(58.9 %)
communicated results to the patient within required time
frames. In addition, for pathology services, the OIG Overall Rating:
determines whether the institution received a final pathology Adequate
report and whether the provider timely reviewed and
communicated the pathology results to the patient. The case reviews also factor in the
appropriateness, accuracy, and quality of the diagnostic test(s) ordered and the clinical response
to the results.
For this indicator, the case review and compliance review processes yielded different results,
with the case reviewers assigning an adequate rating and the compliance testing resulting in an
inadequate score. The main reason for the inadequate score: providers did not timely review
radiology and laboratory reports; in addition, they did not communicate the results to the patient.
The OIG considered results obtained from both case review and compliance testing, and
concluded that the majority of the deficiencies resulted from the inattention of one provider who
did not review diagnostic reports promptly and often did not forward the results to the patients.
Nonetheless, the majority of HDSP providers demonstrated their awareness of the results and
treated their patients appropriately. Despite the one provider’s poor documentation habits, HDSP
patients continued to receive satisfactory diagnostic services. OIG clinicians determined that the
overall rating for this indicator was adequate.
Case Review Results
The OIG clinicians reviewed 63 diagnostic events and found 10 deficiencies, 8 of which were
significant. Of these ten deficiencies, seven were related to health information management and
three were related to the completion of ordered tests.
Test Completion
HDSP completed most diagnostic services promptly. The OIG clinicians observed three
significant deficiencies as explained in the following cases:
• In case 1, the provider requested urgent laboratory tests be performed the next morning.
Instead, HDSP staff performed the tests nine days later.
• In case 5, the provider ordered blood tests, but HDSP staff never completed them.
• In case 9, the provider ordered blood tests and an electrocardiogram (EKG), but HDSP staff
did not perform the EKG and most of the laboratory tests.
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Health Information Management
HDSP experienced some challenges with its health information management of diagnostic
results. The OIG clinicians observed a pattern of one provider not reviewing laboratory test
results and not notifying the patients of these test results as detailed in the following:
• In case 7, the provider did not notify the patient of his test result showing poorly controlled
diabetes.
• In case 9, a patient’s laboratory result was reviewed by a nurse more than a month late, and
his provider did not review it until more than four months later.
• In case 16, the provider did not review the chest X-ray result and, consequently, did not
notify the patient of the results.
Clinician Onsite Inspection
HDSP diagnostic supervisors stated that when results were ready, the EHRS sent the provider a
notification to review the results in the providers’ message center. Whether the provider
reviewed the results timely or at all was beyond diagnostic supervisors’ control. The majority of
the deficiencies noted in this area occurred when providers did not appropriately review their
messages in the EHRS.
Case Review Conclusion
HDSP usually performed well in completing and retrieving diagnostic studies. HDSP did not
perform or delayed only a small fraction of laboratory tests. One provider reviewed diagnostic
results late and did not notify the patient of the results, but this poor practice did not result in a
noticeable effect on the quality of care provided to patients at the institution. The OIG clinicians
rated the Diagnostic Services indicator adequate.
Compliance Testing Results
The institution received an inadequate compliance score of 56.7 percent in the Diagnostic
Services indicator, which encompasses radiology, laboratory, and pathology services. For clarity,
each type of diagnostic service is discussed separately below:
Radiology Services
• While HDSP providers timely performed radiology services for all ten sampled patients
(100 percent) (MIT 2.001), only three of the ten patients (30 percent) received timely
reviews of their corresponding diagnostic services reports. For five patients, HDSP
providers reviewed their reports from one to 21 days late. For the remaining two patients,
OIG inspectors found no medical record evidence that providers reviewed those reports
(MIT 2.002). Providers timely communicated test results to only three of the ten sampled
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patients (30 percent). Providers communicated three patients’ results one to two days late,
and two other patients’ results 26 and 66 days late. For two final patients, OIG inspectors
found no medical record evidence that the results were communicated to them (MIT 2.003).
Laboratory Services
• HDSP providers timely obtained ordered diagnostic services for ten sampled patients
(MIT 2.004). However, providers then signed and dated those laboratory reports for only six
of those ten patients (60 percent); furthermore, providers reviewed four reports from 3 to 21
days late (MIT 2.005). Finally, providers timely communicated laboratory reports’ results to
only three of the ten sampled patients (30 percent); for three patients, communication was
late from 4 to 8 days, and for the remaining four patients, from 20 to 56 days (MIT 2.006).
Pathology Services
• The institution timely received final pathology reports for nine of ten sampled patients
(90 percent), but one patient’s pathology report was received 26 days late (MIT 2.007). For
five of the ten patients (50 percent), HDSP providers timely reviewed the final pathology
reports, but for the other five patients, their final pathology reports were reviewed from two
to ten days late (MIT 2.008). Providers timely communicated final pathology results to only
four of the ten sampled patients (40 percent). For five patients, the provider communicated
pathology results from 2 to 24 days late, and one final patient never received any provider
communication concerning his result (MIT 2.009).
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EMERGENCY SERVICES
An emergency medical response system is essential to
Case Review Rating:
providing effective and timely emergency medical response,
Adequate
assessment, treatment, and transportation 24 hours per day.
Compliance Score:
Provision of urgent/emergent care is based on a patient’s
Not Applicable
emergency situation, clinical condition, and need for a higher
Overall Rating:
level of care. The OIG reviews emergency response services
Adequate
including first aid, basic life support (BLS), and advanced
cardiac life support (ACLS) consistent with the American
Heart Association guidelines for cardiopulmonary resuscitation (CPR) and emergency
cardiovascular care, and the provision of services by knowledgeable staff appropriate to each
individual’s training, certification, and authorized scope of practice.
The OIG evaluates this quality indicator entirely through clinicians’ reviews of case files and
conducts no separate compliance testing element.
Case Review Results
The OIG clinicians reviewed 29 urgent/emergent events and found 22 deficiencies related mostly
to nursing documentation. Only one deficiency was considered significant.
CPR Response
During the review period, three cases required emergency medical CPR responses. In each case,
HDSP performed well with emergency response times, CPR and other emergency interventions,
and 9-1-1 activation. HDSP staff documented the CPR emergency events and medical
interventions clearly, except for one case in which the provider failed to document provider
interventions during the provision of CPR.
Provider Performance
HDSP providers performed well in the emergent setting, properly assessing and triaging their
patients. Providers sent patients requiring a higher level of care to an outside hospital promptly.
HDSP staff appropriately treated those patients not requiring hospitalization in the TTA. The
OIG identified no patterns of deficiencies.
Nursing Performance
As was evident during the Cycle 4 inspection, HDSP nurses continued providing proper care
during emergency responses. They responded promptly to medical emergencies and provided
appropriate interventions.
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Nursing Documentation
HDSP transitioned to the EHRS in January 2017. Nursing leadership acknowledged the
institution’s staff had experienced challenges with completing documentation in the EHRS,
specifically in the TTA. Nursing staff continued to receive periodic training to remedy this
situation.
The OIG clinicians found incomplete chronological information and missing nursing
documentation during their review of emergency medical response encounters. First medical
responders and TTA nurses consistently neglected to document relevant patient information,
such as initial assessments of vital signs, specific times when they contacted the on-call
physician or the 9-1-1 ambulance service, and status updates concerning the patient’s condition
while in the TTA. Additionally, first medical responders did not complete progress notes about
emergency event details, including their nursing assessments and interventions for five events
reviewed in one case. These documentation deficiencies resulted in an inability to precisely and
accurately assess the patient’s clinical condition and determine which interventions the nurses
may have been provided before the patient arrived in the TTA.
However, the OIG clinicians considered the majority of the deficiencies minor because they
usually consisted of incomplete or missing nursing documentation. Although these deficiencies
did not affect the patient’s care, they represent areas the institution can target for quality
improvement.
Emergency Medical Response Review Committee
The Emergency Medical Response Review Committee (EMRRC) appropriately discussed and
identified deficiencies, and documented actions taken to correct problems noted in the
13 emergent medical response cases the OIG clinicians reviewed.
Clinician Onsite Inspection
The TTA was appropriately equipped and well-staffed with nurses trained to handle emergency
events onsite. A provider covered the TTA during business hours, and an on-call provider was
readily available during after-hours. During interviews, TTA nurses reported that nurses from
both the clinics and the CTC assisted during medical emergencies when needed. HDSP also
reported its plan in January 2018 to provide emergency telemedicine services through a
contracted community hospital.
Case Review Conclusion
In general, HDSP’s performance was good, with the majority of deficiencies due to nursing
documentation issues. HDSP staff provided proper care and sent patients to the outside hospital
when needed. For patients with less serious problems, the staff treated, and returned, them to
housing appropriately. The indicator for Emergency Services was rated adequate.
High Desert State Prison, Cycle 5 Medical Inspection Page 26
Office of the Inspector General State of California
HEALTH INFORMATION MANAGEMENT
Health information management is a crucial link in the delivery of
Case Review Rating:
medical care. Medical personnel require accurate information in Adequate
order to make sound judgments and decisions. This indicator Compliance Score:
examines whether the institution adequately manages its health Inadequate
(66.0%)
care information. This includes determining whether the
information is correctly labeled and organized and available in the Overall Rating:
electronic medical record; whether the various medical records Adequate
(internal and external, e.g., hospital and specialty reports and
progress notes) are obtained and scanned timely into the patient’s electronic medical record;
whether records routed to clinicians include legible signatures or stamps; and whether hospital
discharge reports include key elements and are timely reviewed by providers.
In this indicator, the OIG’s case review and compliance review processes yielded different
results, with the case reviewers assigning an adequate rating and the compliance testing resulting
in an inadequate score. The compliance testing score identified problems had occurred with
scanning accuracy, retrieval of specialty consultation reports, and provider review of hospital
discharge reports. There were more samples in the case reviews, which provided a more accurate
representation of these measures. Even though providers did not always sign the hospital
discharge reports, providers demonstrated in their notes that they had properly reviewed the
reports. The OIG’s internal review process considered the factors that led to both results and
determined that the overall rating for this indicator was adequate.
During the OIG’s testing period, HDSP had converted to the new electronic health record system
(EHRS) in January 2017; therefore, most testing occurred in the EHRS, with a minor portion of
the testing done in the electronic unit health record (eUHR).
Case Review Results
The OIG clinicians reviewed 746 events and found 24 deficiencies related to health information
management, 8 of which were significant. Most of the deficiencies involved the provider not
signing reports and consultations.
Inter-Departmental Transmission
During the review period, HDSP transitioned to the EHRS. While HDSP lost one order before
the transition to the new system, after its implementation, no further transmission errors occurred
among the different departments at the institution.
High Desert State Prison, Cycle 5 Medical Inspection Page 27
Office of the Inspector General State of California
Hospital Records
HDSP demonstrated good performance with the retrieval of emergency department and hospital
discharge summaries. The OIG clinicians noted one significant deficiency in which the
institution failed to retrieve the discharge summary for a hospitalization in case 17.
Specialty Services
HDSP’s performance in handling specialty reports was satisfactory. Performance in this area is
also discussed in the Specialty Services indicator.
Diagnostic Reports
HDSP performed poorly with the timely review of diagnostic reports. Performance in this area is
discussed in greater detail in the Diagnostic Services indicator.
Urgent/Emergent Records
HDSP nurses did a poor job documenting their emergency encounters. Performance in this area
is also discussed in the Emergency Services indicator.
Scanning Performance
HDSP performed adequately in this area after transitioning to the EHRS. The OIG identified
minor deficiencies of mislabeled documents in three cases and misdated reports in two cases.
Legibility
At HDSP, legibility was not an issue after the institution transitioned to the EHRS.
Clinician Onsite Inspection
The OIG clinicians observed several morning huddles in the individual clinic. At those meetings,
participants disseminated clinical information about overnight events, new arrivals, recent
transfers, medications soon to expire, and sick call requests. Providers demonstrated familiarity
with their patients.
Case Review Conclusion
HDSP performed well with retrieving outside specialty reports, hospital discharge summaries,
and outside emergency department reports. Scanning time frames were acceptable; scanning
accuracy was satisfactory. There were fewer missing, misfiled, or mislabeled documents after the
EHRS transition. However, the institution experienced difficulty with ensuring providers
reviewed and signed laboratory and hospital discharge summary reports. The nursing
documentation from the TTA was suspect, and this aspect is detailed in the Emergency Services
indicator. Nonetheless, most health information was available to providers when they needed to
review it; thus, the indicator rating was adequate.
High Desert State Prison, Cycle 5 Medical Inspection Page 28
Office of the Inspector General State of California
Compliance Testing Results
The institution scored in the inadequate range with a score of 66.0 percent in the Health
Information Management indicator. The following tests showed room for improvement:
• The institution scored 58 percent for correctly labeling and filing documents scanned into
patients’ electronic medical records. For this test, the OIG bases its score on an allowable
maximum of 24 mislabeled or misfiled documents. For the HDSP medical inspection, OIG
inspectors identified 14 documents that were either mislabeled or missing from the medical
record (MIT 4.006).
• Among eight sampled patients admitted to an outside hospital who then returned to the
institution, HDSP providers timely reviewed five patients’ corresponding hospital discharge
reports within three calendar days of their discharge (62 percent). For the other three
sampled patients, the provider did not sign the hospital discharge report (MIT 4.007).
• For 13 of 20 specialty service consultant reports sampled (65 percent), HDSP staff scanned
the reports into the patient’s health record file within five calendar days. However, HDSP
staff scanned six documents from one to 8 days late and scanned one document 165 days
late (MIT 4.003).
• Institution staff timely scanned 9 of 13 sampled documents, such as non-dictated provider
progress notes, nursing initial health screening forms, and patient health care service request
forms into the patient’s electronic medical record within three calendar days of the patient
encounter (69 percent); HDSP scanned four documents from one to four days late
(MIT 4.001).
One test received a score of adequate:
• HDSP’s records management staff timely scanned outside hospital discharge reports or
treatment records into six of the eight sampled patients’ health records (75 percent), but two
reports were scanned four and ten days late (MIT 4.004).
High Desert State Prison, Cycle 5 Medical Inspection Page 29
Office of the Inspector General State of California
HEALTH CARE ENVIRONMENT
This indicator addresses the general operational aspects of the
Case Review Rating:
institution’s clinics, including certain elements of infection Not Applicable
control and sanitation, medical supplies and equipment Compliance Score:
management, the availability of both auditory and visual privacy Adequate
(76.6%)
for patient visits, and the sufficiency of facility infrastructure to
conduct comprehensive medical examinations. The OIG rates Overall Rating:
this component entirely on the compliance testing results from Adequate
the visual observations inspectors make at the institution during
their onsite visit. This indicator is evaluated entirely by compliance testing. There is no case
review portion.
Compliance Testing Results
The institution received scores in the proficient range on the following four tests:
• All 12 clinics were appropriately clean, disinfected, and sanitary. In addition, cleaning logs
were present and completed, indicating crews regularly cleaned the clinics (MIT 5.101).
• The bulk medical supply storage areas (outside of the clinics) met the supply management
process and support needs of the medical health care program, earning HDSP a score of
100 percent on this test (MIT 5.106).
• Of the 12 clinic locations inspected, 11 of them (92 percent) had operating sinks and
sufficient quantities of hand hygiene supplies in examination areas. One clinic’s patient
restroom did not have sufficient quantities of hygiene supplies such as antiseptic soap
(MIT 5.103).
• Health care staff at 11 of 12 clinics followed proper protocols to mitigate exposure to
blood-borne pathogens and contaminated waste (92 percent). Personal protective equipment
was not available within the immediate area of one clinic (MIT 5.105).
Three tests received scores in the adequate range:
• Clinical health care staff in 9 of the 11 applicable clinics (82 percent) properly sterilized or
disinfected reusable invasive and non-invasive medical equipment. At one location, staff did
not follow adequate sterilization safeguards for invasive medical equipment. At another
location, clinical staff relied on the cleaning crew to disinfect the examination table before
the start of the new shift. The OIG inspectors noted that the staff did not replace protective
paper on the examination table in between patient encounters (MIT 5.102).
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Office of the Inspector General State of California
• Nine of the 12 clinics (75 percent) maintained core equipment or other essential supplies
necessary to conduct comprehensive examinations in their clinic common areas and
examination rooms. Deficiencies in equipment and supplies included the following: one
clinic lacked a demarcation line for the Snellen eye examination chart; another clinic was
missing its nebulization unit; in a third clinic, the oto-ophthalmoscope was not working
during the OIG’s inspection (MIT 5.108).
• Nine of the 12 clinics (75 percent) maintained clinic common areas that were conducive to
providing medical services. In the remaining three clinics, the location of blood draw
stations compromised patients’ auditory privacy (MIT 5.109).
Four tests showed areas in which the institution can improve:
• In 8 of the 11 (73 percent) applicable clinic examination rooms that the OIG observed,
inspectors found appropriate space, configuration, supplies, and equipment to allow
clinicians to perform proper clinical examinations. In two clinic locations, the examination
tables had torn vinyl covers; and in another clinic, no portable screen was available to
provide visual privacy for patients (MIT 5.110).
• OIG inspectors observed clinician encounters with patients in 11 applicable clinics.
Clinicians followed good hand hygiene practices in six clinics (55 percent). At five clinics,
however, clinicians failed to wash their hands before or after patient contact, or before
applying gloves (MIT 5.104).
• In 6 of the 12 clinics inspected (50 percent), the OIG
found that staff followed appropriate medical supply
storage and management protocols. At the remaining
six clinics, the OIG found medical supplies stored
beyond manufacturers’ guidelines; medical supplies
were also inappropriately stored in the same area with
disinfecting agents and personal items (Figure 1)
(MIT 5.107).
• OIG inspectors examined emergency medical
response bags (EMRBs) and the crash cart to
determine whether HDSP staff inspected them daily,
inventoried them monthly, and if they contained all
essential items. EMRBs were compliant in four of the
Figure 1: Medical supplies
eight applicable clinical locations where they were
inappropriately stored with
stored (50 percent). In four locations, the EMRB log
other agents.
was incomplete, as staff had not properly verified that
the bag’s compartments were sealed and intact (MIT 5.111).
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Office of the Inspector General State of California
Non-Scored Results
The OIG gathered information to determine if the institution’s physical infrastructure was
maintained in a manner that supported health care management’s ability to provide timely or
adequate health care. The OIG does not score this question.
• When OIG inspectors interviewed health care managers, they did not identify any significant
concerns. At the time of the OIG’s medical inspection, HDSP had several significant
infrastructure projects underway, which included increasing clinic space at five yards,
expansion of the pharmacy, and expansion of the telemedicine clinic. These projects were
started fall 2016, and the institution estimates they will be completed by the end of summer
2018 (MIT 5.999).
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Office of the Inspector General State of California
INTER- AND INTRA-SYSTEM TRANSFERS
This indicator focuses on the management of patients’ medical
Case Review Rating:
needs and continuity of patient care during the inter- and Adequate
intra-system transfer process. The patients reviewed for this Compliance Score:
indicator include those received from, as well as those Inadequate
(70.3%)
transferring out to, other CDCR institutions. The OIG review
includes evaluation of the institution’s ability to provide and Overall Rating:
document health screening assessments, initiation of relevant Adequate
referrals based on patient needs, and the continuity of
medication delivery to patients arriving from another institution. For those patients, the OIG
clinicians also review the timely completion of pending health appointments, tests, and requests
for specialty services. For patients who transfer out of the institution, the OIG evaluates the
ability of the institution to document transfer information that includes pre-existing health
conditions, pending appointments, tests and requests for specialty services, medication transfer
packages, and medication administration prior to transfer. The OIG clinicians also evaluate the
care provided to patients returning to the institution from an outside hospital and check to ensure
appropriate implementation of the hospital assessment and treatment plans.
In this indicator, the OIG’s case review and compliance review process yielded different results,
with the case reviewers assigning an adequate rating and the compliance testing resulting in an
inadequate score. HDSP scored zero on one compliance test for incomplete transfer packets, and
this test adversely affected the overall compliance score. However, the incomplete transfer
packets were not clinically significant in the cases reviewed by the OIG clinicians. The OIG’s
internal review process considered those factors that led to both results and rated this indicator
adequate.
Case Review Results
The OIG clinicians reviewed 37 inter- and intra-system transfer events, including information
from both the sending and receiving institutions. These included 21 hospitalizations and outside
emergency room events, each of which resulted in a transfer back to the institution.
Transfers In
HDSP performed acceptably with ensuring that patients who transferred from another CDCR
institution received sufficient health care. The OIG clinicians reviewed ten such cases. Two
transfer-in cases showed room for improvement:
• In case 22, the high-risk patient with a history of stroke, paralysis on his right side, and
hypertension arrived. The receiving nurse did not schedule a provider follow-up
appointment within seven days after arrival, as required by CCHCS policy. The provider
evaluated the patient more than a month later, but neither documented a progress note nor
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Office of the Inspector General State of California
ordered a follow-up appointment. HDSP stopped the patient’s care. Four months later,
HDSP still had not scheduled a provider follow-up for the patient.
• In case 31, the receiving nurse scheduled a provider follow-up within 14 days, but staff
inappropriately canceled the appointment. Fortunately, a provider saw the patient more than
a month later due to his medication refusals.
In four additional transfer-in cases, the OIG identified minor deficiencies, which included the
following concerns: delays in provider appointments for newly arrived patients, a mislabeled
form scanned into the electronic health record, and incomplete nursing assessment information
listed on the initial health screening form.
Transfers Out
The OIG clinicians reviewed six cases in which patients transferred from HDSP to other CDCR
institutions. The transfer-out process in all six cases was good.
Hospitalizations
Patients returning from hospitalizations are some of the highest-risk encounters due to two
factors. First, these patients usually require hospitalization for a severe illness or injury, and
second, they are at risk due to potential lapses in care that can occur during any transfer.
The HDSP health care team performed well in the hospital transfer process. The OIG clinicians
reviewed the records for 21 patients who had returned to HDSP from an offsite hospital
admission or an emergency department visit. HDSP nurses properly processed most patients
returning from the hospital through the TTA. Compared to Cycle 4, the TTA nurses have
significantly improved the quality of their assessments for patients returning from the hospital.
Clinician Onsite Inspection
The receiving and release (R&R) health care area had sufficient space in which to conduct initial
health care screenings. HDSP staff sent transfer notifications weekly, and the first-watch RN
reviewed the health care transfer information. One RN covered each shift on business days, and
administrative staff assisted in processing patient intakes and transfers four days per week.
Case Review Conclusion
HDSP performed sufficiently for patients who transferred into or out of the institution. The
health care staff did well in ensuring continuity of care for those patients who transferred from an
outside hospital. Overall, the OIG clinicians found the transfer processes at HDSP adequate.
High Desert State Prison, Cycle 5 Medical Inspection Page 34
Office of the Inspector General State of California
Compliance Testing Results
The institution scored in the inadequate range for this indicator, with a score of 70.3 percent. The
institution can improve in the following area:
• During the onsite inspection, HDSP received a score of zero when the OIG inspectors tested
nine patients transferring out of the institution to determine whether the patients’ transfer
packages included required medications and related documentation. The OIG identified nine
packages with one or more of the following deficiencies: transfer packages were missing the
required transfer checklist forms and medications noted on patients’ active medication lists,
and the OIG identified at least one medication for which there was no active medication
order (MIT 6.101).
Two tests received scores in the adequate range:
• OIG inspectors tested 20 patients who transferred out of HDSP to other CDCR institutions
to determine whether their previously scheduled specialty service appointments were listed
on the health care transfer form. HDSP nursing staff identified these scheduled appointments
on the transfer form for 15 of the 20 samples tested (75 percent), but for the remaining five
patients, staff did not identify pending specialty service appointments on the transfer forms
(MIT 6.004).
• Seventeen sampled patients transferred to HDSP from other CDCR institutions with existing
medication orders that required nursing staff to issue or administer medications to them
upon their arrival. Of those patients, 13 of them (77 percent) received their medications
timely, but the remaining 4 patients did not receive their medications at the next dosing
interval as CCHCS policy requires (MIT 6.003).
One test received a score of proficient:
• For 25 patients newly arriving at HDSP from other CDCR institutions, nursing staff
properly documented an assessment and disposition of the Initial Health Screening form
(CDCR Form 7277), signing and dating the form on the same day the patient arrived at
HDSP (MIT 6.001, 6.002).
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Office of the Inspector General State of California
PHARMACY AND MEDICATION MANAGEMENT
This indicator is an evaluation of the institution’s ability to
Case Review Rating:
provide appropriate pharmaceutical administration and Inadequate
security management, encompassing the process from the Compliance Score:
written prescription to the administration of the medication. Inadequate
(68.8%)
By combining both a quantitative compliance test with case
review analysis, this assessment identifies issues in various Overall Rating:
stages of the medication management process, including Inadequate
ordering and prescribing, transcribing and verifying,
dispensing and delivering, administering, and documenting and reporting. Because numerous
entities across various departments affect medication management, this assessment considers
internal review and approval processes, pharmacy, nursing, health information systems, custody
processes, and actions taken by the prescriber, staff, and patient.
Case Review Results
The OIG clinicians evaluated 46 events related to medications and found 18 deficiencies, 6 of
which were significant. HDSP’s medication processes were problematic.
Medication Continuity
HDSP did not ensure that nurses administered chronic care medications continuously. The
patients experienced breaks in the continuity of chronic medications in cases 9, 10, 13, 15, 16,
17, and the following two cases:
• In case 11, breaks occurred in administering the patient’s keep-on-person (KOP)
medications. In February, March, and May 2017, the patient did not receive some of his
medications.
• In case 12, breaks occurred in administering the patient’s chronic care medications. In
May and June 2017, the patient did not receive some of his medications.
Medication Administration
At times, HDSP nurses were unable to administer prescribed medications timely or accurately.
The nurses documented various reasons for not administering medications; examples included:
the patient did not show up to receive his monthly KOP medications, custody did not release the
patient to pick up his medications, nurses did not request medication refills, or the medications
were not available. One major problem was that when the patient arrived at the next medication
administration time, the nurses still did not issue the patient’s KOP medications. The OIG
clinicians identified these deficiencies in cases 11, 12, 13, 16, and the following case:
High Desert State Prison, Cycle 5 Medical Inspection Page 36
Office of the Inspector General State of California
• In case 17, the provider ordered Tamiflu (a medication used to treat the influenza virus), but
the patient did not receive the medication. The nurse documented in the EHRS that the
patient did not come to pick up his medication. However, the nurse also entered
contradictory documentation showing the nurse administered the patient’s other medications
at the same time that the nurse should have given the Tamiflu.
Pharmacy Errors
HDSP had one deficiency in the pharmacy process as outlined in the following example:
• In case 15, the provider ordered sumatriptan to be dispensed the next day, but the patient did
not receive it until 25 days later.
Clinician Onsite Inspection
The OIG clinicians discussed the concerns identified during their review with the nursing and
pharmacy supervisors, who explained the challenges their staff faced during the EHRS transition.
The new system automatically, and erroneously, initiated medication orders without receiving
requests from either the provider or the patient. The EHRS did not route the orders to the
pharmacy, so the pharmacy did not dispense any medication. Because the EHRS considered the
faulty orders valid, the system required the nurses to document the administration of the
non-existent medications. Furthermore, the EHRS would not allow staff to proceed with their
other, valid tasks without first addressing the invalid orders by entering a response into the
system. Thus, nurses who needed to complete their work would select various options at random
and input them into the EHRS to answer why they did not administer these incorrectly ordered
medications. Some chose to enter “medication not given; medication not available,” while others
chose “late; nursing judgment.” This error-laden process explained some of the deficiencies the
OIG clinicians identified.
HDSP supervisors explained a second problem. Nursing staff often would place medications in
storage areas, but then would fail to look in these areas when it came time to administer
medications to their patients. Instead of retrieving these stored medications, the nurses would
erroneously document that the medications were inexplicably “missing” or could not be located.
The nurses would then repeatedly request refills from the pharmacy, which resulted in an
excessive supply of medications in the clinic. HDSP was developing policies and training to
manage their medications more effectively.
Case Review Conclusion
The EHRS transition caused complications in the workflow between the pharmacy and the clinic.
The faulty system-generated orders created confusion for the nurses and resulted in the erroneous
documentation. HDSP was working on training its nursing staff, so they could learn how to
update their patients’ records properly in the EHRS in these situations. Nonetheless, due to the
unreliable nature of HDSP’s medication documentation process, sometimes, it was impossible to
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Office of the Inspector General State of California
determine whether patients had received their medications. The case review clinicians rated the
Pharmacy and Medication Management indicator inadequate.
Compliance Testing Results
The institution received a score of 68.8 percent in the Pharmacy and Medication Management
indicator. For discussion purposes below, this indicator is divided into three sub-indicators:
medication administration, observed medication practices and storage controls, and pharmacy
protocols.
Medication Administration
For this sub-indicator, the institution received an inadequate score of 69.1 percent. The following
test showed room for improvement:
• Among 16 applicable sampled patients, 6 of them (37 percent) timely received their chronic
care medications timely. Three patients did not receive their KOP medications as ordered;
seven others received “nurse administered” medications one to five days late (MIT 7.001).
Three tests earned scores in the adequate range:
• Of the 25 sampled patients at HDSP who transferred from one housing unit to another, 21 of
them (84 percent) received their prescribed “nurse administered” medications without
interruption. Four patients did not receive their medications at the next dosing interval after
the transfer occurred as required by CCHCS policy (MIT 7.005).
• HDSP timely administered or delivered new medications as ordered to 20 of the 25 sampled
patients (80 percent). Of the five patients who did not receive their medication timely,
HDSP staff delayed three patients’ initial doses from one to two days; for two others, HDSP
staff did not give the medications at all (MIT 7.002).
• Clinical staff timely provided new and previously prescribed medications to six of eight
patients sampled who had been discharged from a community hospital and returned to the
institution (75 percent). For two patients, the medical record revealed no evidence that they
received their ordered “nurse administered” medication (MIT 7.003).
Observed Medication Practices and Storage Controls
The institution scored 62.6 percent in this sub-indicator, with the following tests scoring in the
inadequate range:
• The institution received a score of zero when the OIG inspected medication preparation and
administration areas to determine whether clinical staff demonstrated appropriate
administrative controls and protocols. In six locations, one or more of the following
deficiencies were identified: patients waiting to receive their medications did not have
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Office of the Inspector General State of California
sufficient outdoor cover to protect them from heat or inclement weather; the medication
nurse did not always ensure that patients swallowed direct observation therapy medication;
and the medication nurse did not always verify patients’ identities by a picture form of
identification (MIT 7.106).
• The institution employed adequate security controls over narcotic medications in two of the
seven applicable clinic and medication line locations where narcotics were stored
(29 percent). At five clinics, the following deficiencies were identified: the narcotics
logbook showed that on multiple occasions, controlled substance inventory counts were not
performed by two nurses; nurses left narcotic medications unsecured on top of the
medication cart; and nurses did not counter-sign the narcotics logbook to verify the proper
destruction of controlled substances (MIT 7.101).
• Inspectors observed the medication preparation and administration processes at six
applicable medication administration locations. The nursing staff was compliant with proper
hand hygiene and contamination control protocols at four locations (67 percent). At two
locations, some nursing staff did not wash or sanitize their hands before subsequent
re-gloving (MIT 7.104).
Three tests received scores of proficient:
• HDSP properly stored refrigerated non-narcotic medications in eight of nine clinics and
medication line storage locations (89 percent). At one location, however, a medication
refrigerator was not sanitary (MIT 7.103).
• HDSP properly stored non-narcotic medications that did not require refrigeration in 11 of
the 12 (92 percent) applicable clinics and medication line storage locations. In one location,
nurses did not label a multi-use medication with the date staff opened it (MIT 7.102).
• Nursing staff at all six of the inspected medication line locations employed appropriate
administrative controls and followed appropriate protocols during medication preparation
(MIT 7.105).
Pharmacy Protocols
HDSP scored 76 percent in this sub-indicator, with the following tests earning proficient scores:
• HDSP’s main pharmacy followed general security, organizational, and cleanliness
management protocols. In addition, the institution properly stored non-refrigerated and
refrigerated medications in the main pharmacy (100 percent) (MIT 7.107, 7.108, 7.109).
The following test received an adequate score:
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Office of the Inspector General State of California
• The institution’s pharmacist in charge (PIC) followed required protocols for 20 of the
25 medication error reports and monthly statistical reports reviewed (80 percent). For four
medication error reports, the PIC completed corresponding medication error follow-up
review (CDCR Form 7541) reports from 3 to 37 days late, but for one, the OIG inspectors
found no evidence the PIC had completed this report (MIT 7.111).
The following test showed room for improvement:
• OIG inspectors also reviewed monthly controlled substance inventories in the institution’s
clinical and medication line storage locations, and they found several Medication Area
Inspection Checklist forms (CDCR Form 7477) missing the name, signature, and date of the
pharmacist in charge (PIC) responsible for completing each inventory record. As a result,
the institution received a score of zero in this test (MIT 7.110). However, in HDSP’s main
pharmacy, the PIC properly accounted for narcotic medications stored there.
Non-Scored Tests
• In addition to the OIG’s testing of reported medication errors, inspectors follow up on any
significant medication errors found during compliance testing to determine whether HDSP
properly identified and reported errors. The OIG provides those results for information
purposes only. At HDSP, the OIG did not find any applicable medication errors
(MIT 7.998).
• The OIG interviewed patients housed in isolation units to determine whether they had
immediate access to their prescribed KOP rescue inhalers and nitroglycerin medications.
Ten applicable patients interviewed indicated they had access to their rescue medications
(MIT 7.999).
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Office of the Inspector General State of California
PRENATAL AND POST-DELIVERY SERVICES
This indicator evaluates the institution’s capacity to provide
Case Review Rating:
timely and appropriate prenatal, delivery, and postnatal services
Not Applicable
to pregnant patients. This includes the ordering and monitoring of
Compliance Score:
indicated screening tests, follow-up visits, referrals to higher
Not Applicable
levels of care, e.g., high-risk obstetrics clinic, when necessary,
Overall Rating:
and postnatal follow-up.
Not Applicable
As HDSP does not have female patients, this indicator does not
apply.
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Office of the Inspector General State of California
PREVENTIVE SERVICES
This indicator assesses whether the institution offered or
Case Review Rating:
provided various preventive medical services to patients. These Not Applicable
include cancer screenings, tuberculosis screenings, and influenza Compliance Score:
and chronic care immunizations. This indicator also assesses Adequate
(81.3%)
whether certain institutions take preventive actions to relocate
patients identified as being at higher risk for contracting Overall Rating:
coccidioidomycosis (valley fever). Adequate
The OIG rates this indicator entirely through the compliance testing component; the case review
process does not include a separate qualitative analysis for this indicator.
Compliance Testing Results
The institution scored in the adequate range for this indicator at 81.3 percent. The following
three tests were in the proficient range:
• HDSP offered annual influenza vaccinations to all 25 sampled patients subject to the annual
screening requirement (MIT 9.004).
• The OIG found that 28 of 30 (93 percent) sampled patients received annual tuberculosis
(TB) screenings. For two patients, the annual TB screening did not occur during their birth
months as required by current CCHCS policy (MIT 9.003).
• The OIG found that HDSP successfully screened 24 of 25 sampled patients (96 percent) for
colorectal cancer. The patients underwent a colonoscopy procedure within the past ten years
or were offered colorectal cancer testing within the previous 12 months (MIT 9.005).
One test received an adequate score:
• The OIG reviewed HDSP’s monitoring of nine sampled patients who received
TB medications and found the institution in compliance for seven patients (78 percent). For
two patients, OIG inspectors found no documentation of the required monitoring
(MIT 9.002).
Two tests revealed the institution could improve in this area:
• The OIG tested whether HDSP offered required influenza, pneumonia, and hepatitis
vaccinations to patients who suffered from a chronic condition; 13 of the 20 sampled
patients (65 percent) received the required vaccines. For the other seven patients, the OIG
found no evidence that the patients received or refused their required vaccinations
(MIT 9.008).
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Office of the Inspector General State of California
• HDSP scored poorly in administering TB medications timely. The OIG examined health
care records for nine patients who were on TB medications during the inspection period;
only five patients received all their required medications (56 percent). Four patients missed
scheduled doses, and none of them received the requisite provider counseling regarding
missed doses (MIT 9.001).
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QUALITY OF NURSING PERFORMANCE
The Quality of Nursing Performance indicator is a qualitative
Case Review Rating:
evaluation of the institution’s nursing services. The evaluation
Adequate
is completed entirely by OIG nursing clinicians within the case
Compliance Score:
review process and does not have a score under the OIG
Not Applicable
compliance testing component. Case reviews include
Overall Rating:
face-to-face encounters and indirect activities performed by
Adequate
nursing staff on behalf of the patient. Review of nursing
performance includes all nursing services performed onsite,
such as outpatient, inpatient, urgent/emergent, patient transfers, care coordination, and
medication management. The key focus areas for evaluation of nursing care include
appropriateness and timeliness of patient triage and assessment, identification and prioritization
of health care needs, use of the nursing process to implement interventions, and accurate,
thorough, and legible documentation. Although the OIG reports nursing services provided in
specialized medical housing units in the Specialized Medical Housing indicator, and those
provided in the TTA or related to emergency medical responses in the Emergency Services
indicator, this Quality of Nursing Performance indicator summarizes all areas of nursing
services.
Case Review Results
The OIG clinicians reviewed 287 nursing encounters, 177 of which were in the outpatient
setting. Most outpatient nursing encounters were for sick call requests, care coordination, and
RN follow-up visits. There were 65 deficiencies identified related to the overall performance of
nursing care, 4 of which were significant. The OIG clinicians considered the majority of nursing
deficiencies minor. These resulted from insufficient assessment or incomplete documentation.
The OIG clinicians identified the same pattern of deficiencies in the Cycle 4 medical inspection,
which persists in this cycle. The OIG clinicians rated this indicator adequate.
Nursing Assessment
The majority of HDSP nurses assessed patients appropriately. They asked for a history of the
patient’s complaint and requests for medical care, reviewed the medical records, and provided a
thorough physical examination. However, in some cases, nurses did not complete basic
assessments such as checking vital signs, ascertaining pain levels, asking patients to describe
their symptoms, or examining pertinent areas of the patient’s body related to the complaints.
Nonetheless, the OIG clinicians considered most of these nursing assessment deficiencies minor.
Nursing Intervention
HDSP nurses provided appropriate and timely nursing interventions. Key factors in providing
nursing interventions included addressing all of the patient’s complaints during the nursing
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Office of the Inspector General State of California
encounter, referring the patient to the provider when needed, and providing education or
instructions to the patient. The OIG clinicians identified significant deficiencies in only two of
the cases reviewed in which nurses did not recognize the need to intervene appropriately:
• In case 30, the patient submitted a sick call request stating his balance had worsened. He
was dizzy every day, and he was afraid he would fall down in his cell. The patient had an
upcoming provider appointment in three weeks. The nurse failed to recognize the need to
refer the patient to the provider urgently. In addition, the nurse did not assess the patient for
possible orthostatic hypotension (a drop in his blood pressure) associated with positional
changes (e.g., from sitting or lying down to standing) and to evaluate whether the patient’s
current housing placement was appropriate given possible concerns over his safety.
• In case 35, the patient submitted a sick call request stating he had recently seen the
dermatologist who noted the presence of a skin infection. The dermatologist recommended
two specific medications for treatment. The patient had not received the medications and
stated his skin condition was spreading across his face and head. Nonetheless, the nurse did
not examine the patient’s skin. The nurse also did not review the dermatologist’s
recommendations, did not determine whether the provider had ordered the medications, and
did not contact the provider for further instructions.
Nursing Documentation
Nursing documentation at HDSP was usually appropriate and corroborated the delivery of good
nursing care. The OIG clinicians found only minor documentation deficiencies that occurred
mostly during emergent medical events. These deficiencies are discussed in the Emergency
Services indicator.
Nursing Sick Call
The OIG clinicians reviewed 98 nursing sick call visits. In this area, HDSP nurses demonstrated
good care and nursing competence. HDSP nurses promptly reviewed sick call requests and
assessed patients with medical symptoms. However, the OIG identified two significant
deficiencies in which nurses failed to recognize potentially urgent conditions while reviewing
sick call requests, which should have prompted the nurses to assess the patients the same day as
detailed in the following cases:
• In case 15, the patient submitted a sick call request complaining of fever, coughing up
blood, and the inability to keep fluids down. The nurse did not assess the patient on the same
day and instead wrote on the sick call form that the patient would see the provider. The
provider evaluated the patient two days later.
• In case 38, the patient submitted a sick call request for influenza symptoms. These included
a sore throat, an earache, and a high fever, but the nurse did not assess him until the next
day.
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Care Management/Care Coordination
The LVN care coordinators routinely conducted face-to-face assessments with an assigned group
of patients for systematic monitoring and management of their health care needs. HDSP
improved the care coordination process compared to Cycle 4. For example, care coordinators
monitored and followed up with their patients timely. They usually performed a thorough review
of their patients’ medical records, which included recent diagnostic results, blood pressure
readings, and blood sugar levels. During the onsite inspection, the OIG clinicians observed the
care coordinators using visual aids to teach patients about their disease processes and care
management.
While most care coordination was good, the following are examples of minor deficiencies in this
area:
• In case 2, the patient’s pulse rate was low during a care coordinator visit. The nurse
informed the provider who ordered a re-check of the patient’s pulse rate in two hours. The
nurse did not check the patient’s pulse rate as ordered.
• In case 12, the nurse did not thoroughly review the patient’s medical record and failed to
recognize that the nurses had not performed the ordered weekly blood pressure checks.
Urgent/Emergent Care
First medical responders and TTA nurses provided excellent care during emergent medical
responses. The nurses were prompt, skilled, and well organized during these events. Although
the nurses did not always document pertinent information such as emergent event timelines,
initial nursing assessments, and nursing interventions, these minor deficiencies did not affect the
care delivered. Nursing care in this area is further discussed in the Emergency Services indicator.
Transfers and Post-Hospital Returns
Nursing performance in this area was good. Compared to the Cycle 4 medical inspection, the
TTA nurses had greatly improved with their provision of adequate assessments for patients
returning from the hospital.
Medication Administration
HDSP nurses performed poorly when administering medications. In several cases, patients did
not receive their KOP medications timely. These deficiencies are also discussed in the Pharmacy
and Medication Management indicator.
Specialized Medical Housing
Nurses provided good care to patients in the CTC, with no significant deficiencies identified in
the cases reviewed.
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Offsite Specialty Services Returns
Nurses processed patients returning from offsite specialty appointments through the TTA. The
OIG clinicians found that nurses did not usually inform the provider of the specialist’s findings
and recommendations when patients were seen in the telemedicine specialty clinic. At HDSP,
nursing managers were already aware of this issue and agreed such lapses could potentially delay
necessary health care services, which could affect patient outcomes.
Clinician Onsite Inspection
During their inspection, the OIG clinicians attended morning huddles in the clinics and the CTC,
visited the clinic areas, and interviewed the nurses. Huddle content was complete, and the staff
held in-depth patient care discussions. Schedulers were present to facilitate appointment changes
as needed. Additionally, nurse-staffing levels in the outpatient clinics, R&R, CTC, and TTA
were appropriate for patient needs. Some outpatient clinics and medication rooms had higher
nurse-staffing levels based on requirements for a higher security level or patient populations with
special needs. The nurses were knowledgeable about their clinical assignments and had
participated in different training programs for the institution’s various nursing positions. Nursing
leadership remained actively involved in continuously improving nursing services, and nursing
staff expressed feelings of overall job satisfaction.
The OIG nurse clinician also met with the chief nurse executive (CNE) and the supervising
RN III to discuss specific cases reviewed, along with other nursing issues identified during the
onsite visit. HDSP’s nursing managers readily addressed the cases reviewed, acknowledged the
nursing issues needing improvement, and described their plans of action. The OIG clinicians also
reviewed nursing supervisor and training files, which indicated that quarterly performance
discussions had occurred between supervisors and staff, as well as yearly training sessions on
required nursing competency skills, such as emergency medical response and nursing protocols.
Case Review Conclusion
The institution’s patients generally received good nursing care. The institution should view
nursing deficiencies identified in this indicator as potential areas to improve quality. The OIG
case review clinicians rated the Quality of Nursing Performance indicator adequate.
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Office of the Inspector General State of California
QUALITY OF PROVIDER PERFORMANCE
In this indicator, the OIG physicians provide a qualitative
Case Review Rating:
evaluation of the adequacy of provider care at the institution. The
Adequate
case review clinicians review the provider care regarding
Compliance Score:
appropriate evaluation, diagnosis, and management plans for
Not Applicable
programs including, but not limited to, nursing sick call, chronic
Overall Rating:
care programs, TTA, specialized medical housing, and specialty
Adequate
services. OIG physicians alone assess provider care. There is no
compliance testing component associated with this quality
indicator.
Case Review Results
The OIG clinicians reviewed 130 medical provider encounters and identified 32 deficiencies
related to provider performance, 20 of which were significant. Of the 20 detailed cases reviewed,
one received a proficient rating, 15 received adequate ratings, and 4 received inadequate ratings.
Assessment and Decision-Making
In the majority of encounters, HDSP providers made sound assessments and decisions. While the
majority of the assessments and decisions were good, there was room for improvement. The
following cases present examples of poor assessments or decisions:
• In case 8, the provider knew that the patient was about to start a religious fast, but did not
adjust the patient’s diabetes medications to reduce the risk of fluctuating blood sugar levels.
• In case 10, the provider started the patient on opioid medication, but this patient had a
history of substance abuse. At a follow-up appointment, the provider did not thoroughly
assess the patient’s ability to perform normal daily activities and continued the opioid
medication without proper justification. Given the patient’s substance abuse history, the
provider should have ensured that there was a good reason to continue the opioid
medication.
• Also in case 10, the provider did not examine the patient’s lungs during a chronic care
appointment even though a chief complaint was shortness of breath.
Additionally, there was also a noticeable pattern of certain providers not ordering follow-up
appointments. This pattern occurred in cases 7, 8, 9, and 26.
Review of Records
HDSP providers promptly reviewed diagnostics, medications, outside hospital reports, and
specialty reports with only a few exceptions. Some deficiencies were due to simple provider
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Office of the Inspector General State of California
oversight and were of no great consequence, but other deficiencies were significant. The
following cases offer examples:
• In case 7, the provider did not review the patient’s records when he refused an appointment.
This error led to a two months’ lapse in care.
• In case 9, the patient’s test result showed his diabetes was severely out of control. The
provider failed to review the test result, which caused a lapse in care. Eventually, the nurse
saw the patient one and a half months later, and then the nurse requested a follow-up
appointment.
• In case 10, the provider did not thoroughly review the patient’s medications. The provider
prescribed a second non-steroidal anti-inflammatory (NSAID) drug, which was
contraindicated. The second medication increased the risk of gastrointestinal or kidney
damage, or heart failure.
• In case 16, the provider did not review the laboratory results and did not review the tests
when seeing the patient a few days later. The provider missed these opportunities to evaluate
the patient’s hepatitis C status.
Chronic Care
Patients at HDSP were mostly healthy. Only one patient was taking anticoagulation medication,
and HDSP providers managed his condition well. Management of hypertension, heart disease,
and pulmonary disease at the institution was acceptable.
Diabetes care was inconsistent because several of the patients reviewed refused to take their
medications or were intermittently refusing medications. This situation made it difficult for
providers to deliver proper care. Most diabetic care deficiencies resulted from providers failing
to order follow-up appointments or failing to address diabetes concerns during chronic care
appointments. The following cases provide examples:
• In case 7, the patient was an intermittently compliant diabetic patient with uncontrolled
blood sugar levels. Although the nurses checked his blood sugar levels regularly, the
provider did not adjust the medications to help improve the diabetic control. When the
patient refused a chronic care visit, the provider failed to reschedule the appointment and
allowed the patient’s chronic care visits to lapse.
• In case 8, the patient took a test, which showed uncontrolled diabetes. The provider
reviewed the result, but failed to order a follow-up appointment, resulting in a lapse in care.
Fortunately, the nurse reviewed the result 25 days later and ordered a provider follow-up.
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• In case 9, the provider failed to address the patient’s diabetes during his chronic care visit
and also failed to order a chronic care follow-up appointment, with both elements
contributing to a lapse in the patient’s diabetic care.
Specialty Services
HDSP providers referred patients appropriately. They reviewed specialty services and made
proper assessments except in the following instance:
• In case 11, the provider did not adequately review the cardiology recommendations and did
not order a follow-up appointment for the patient with the cardiologist.
Emergency Care
TTA providers at the institution performed well. They made accurate assessments and
demonstrated good decision-making skills in caring for their patients. These aspects are further
discussed in the Emergency Services indicator.
Specialized Medical Housing
HDSP providers performed well in the CTC. This performance is further discussed in the
Specialized Medical Housing indicator.
Clinician Onsite Inspection
As in Cycle 4, HDSP providers again described their morale as poor. Since July 2016, HDSP had
lost two more providers. One mid-level provider had retired, and another was on medical leave.
The remaining providers lamented the lack of physician leadership, but they praised their CEO
for providing administrative leadership wherever possible. They repeatedly pleaded for more
providers and were distraught over the EHRS. The system severely reduced their productivity at
the time of its implementation. By the time of the onsite inspection, the providers believed that
they had nearly returned to their previous collective level of productivity. The providers
expressed dissatisfaction with what they perceived as a focus on productivity to the exclusion of
providing a high level of patient care.
One mid-level provider was responsible for a disproportionately large share of the provider
deficiencies. This provider did not review diagnostic results and reports either timely or
thoroughly, and often did not address all relevant issues during patient evaluations; for example,
often improperly marking patients’ appointments “completed” even when not addressing the
reasons for the visits. The provider often exacerbated the situation when failing to order
follow-up appointments. At times, the provider did not complete a progress note until months
later. In Cycle 4, the OIG noted similar deficiencies for this same individual, who had offered
similar explanations for personal errors made at that time. The provider attributed the errors to
being overworked; in addition to staffing a regular clinic, the provider staffed evening clinics
twice a week and covered weekend clinics as well. Despite CCHCS recently assigning an offsite
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physician to provide remote supervision, this provider expressed receiving insufficient support
and supervision.
Both the CME and CP&S positions were vacant at the time of the OIG’s onsite inspection. The
OIG clinicians discussed provider care with the individual providers and with the regional
deputy medical executive (DME). After months, if not years, of vacancy, HDSP had just hired a
CP&S and a CME, both of whom started after the OIG’s onsite inspection. HDSP was also
scheduled to implement emergency department services via telemedicine in the upcoming weeks
in an attempt to reduce the institutional providers’ on-call workloads. The regional DME
complimented the performance of his providers, who were working under difficult
circumstances. He attributed the institution’s chronic state of understaffing to HDSP’s remote
locale, as well as its lower compensation rate compared to that offered by other CDCR
institutions. HDSP providers did not receive the additional 15 percent recruitment and retention
pay differential that other CDCR providers had received in July 2017.
Case Review Conclusion
HDSP providers performed well in emergent situations, in the CTC, and for specialty care. As a
whole, the providers exhibited good decision-making skills, with the exceptions of insufficiently
reviewing patients’ medical records and overlooking certain aspects of diabetes care.
The OIG clinicians considered the situation of chronic understaffing, the lack of physician
leadership and supervision, the disproportionate number of errors by one overworked provider,
and the difficulty of providing care to patients who sometimes refused appointments and
medications. These elements likely contributed to both the insufficient record review and the
poor diabetic care. Because other systematic concerns could reasonably explain the provider
challenges identified in the cases reviewed, the OIG clinicians ultimately rated this indicator only
just adequate.
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RECEPTION CENTER ARRIVALS
This indicator focuses on the management of medical needs and
Case Review Rating:
continuity of care for patients arriving from outside the CDCR
Not Applicable
system. The OIG review includes evaluation of the ability of the
Compliance Score:
institution to provide and document initial health screenings,
Not Applicable
initial health assessments, continuity of medications, and
Overall Rating:
completion of required screening tests; address and provide
Not Applicable
significant accommodations for disabilities and health care
appliance needs; and identify health care conditions needing
treatment and monitoring. The patients reviewed for reception center cases are those received
from non-CDCR facilities, such as county jails.
HDSP does not have a reception center; therefore, this indicator does not apply.
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SPECIALIZED MEDICAL HOUSING
This indicator addresses whether the institution follows
Case Review Rating:
appropriate policies and procedures when admitting patients to Adequate
onsite inpatient facilities, including completion of timely nursing Compliance Score:
and provider assessments. The case review assesses all aspects of Adequate
(77.5%)
medical care related to these housing units, including quality of
provider and nursing care. HDSP’s only specialized medical Overall Rating:
housing unit is a correctional treatment center (CTC). Adequate
Case Review Results
In the institution’s CTC, there were 20 medical beds, ten mental health crisis beds, and two
observation rooms. HDSP used ten negative pressure rooms for new admissions and mental
health patients. The OIG clinicians reviewed six CTC admissions, including 35 provider
encounters and 36 nursing encounters. Most of the nursing encounters included a review of
several consecutive days of nursing care. Seven minor deficiencies were identified, consisting of
inadequate nursing assessment, incomplete documentation, and a provider’s lapse in visiting
assigned patients within the time frames specified by CCHCS policy.
Provider Performance
HDSP had one provider assigned to the CTC and the TTA with cross coverage rendered by other
providers when the assigned provider was unavailable. Providers performed well with offering
accurate assessments and demonstrated good decision-making skills. However, they did not
consistently see patients within the 72-hour time frame specified by CCHCS policy, with this
lapse occurring four times in one case.
Nursing Performance
HDSP nurses continued providing the same level of adequate nursing care to CTC patients as
they had during the Cycle 4 inspection. No significant deficiencies were identified in the cases
reviewed.
Clinician Onsite Inspection
During the inspection, the OIG clinicians attended the CTC morning huddle that HDSP had
recently implemented. In addition to the CTC health care and custody team, the TTA RN and
pharmacist also attended the huddle. The CTC shift lead RN coordinated the huddle discussion
similarly to the process established in the outpatient clinic huddles. The team discussed both
medical and mental health patients, including those who were hospitalized at an external facility.
At the time of the OIG’s onsite visit, there were two mental health patients and seven medical
patients in the CTC. In addition, two medical patients were hospitalized at an external facility.
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The primary CTC provider was a temporary, contracted physician. HDSP assigned one shift
lead RN, two RNs, and an LVN to the CTC at all times. A psychiatric technician was also
available during the second and third watches to assist with patient care. The shift lead RN could
describe each nurse’s responsibilities and demonstrated sufficient knowledge of CTC
procedures.
Case Review Conclusion
Providers and nurses at HDSP provided appropriate and timely care in the CTC. The OIG
clinicians rated the Specialized Medical Housing indicator adequate.
Compliance Testing Results
The institution received a score of 77.5 percent in this indicator. Three tests earned scores in the
proficient range:
• When OIG inspectors observed the condition of call buttons in the CTC patient rooms, they
found those that were tested were all working properly. In addition, according to staff
members interviewed, custody officers and clinicians could expeditiously access patients’
locked rooms when emergent events occurred (MIT 13.101).
• For 9 of the 10 sampled patients (90 percent), nursing staff timely completed an initial
health assessment on the day the patient entered the CTC. For one patient, OIG inspectors
found no medical record evidence a registered nurse had completed an assessment
(MIT 13.001).
• HDSP providers evaluated 9 of 10 sampled patients (90 percent) within 24 hours of
admission to the CTC, with only one patient evaluated a day late (MIT 13.002).
One test did indicate room for improvement:
• When OIG inspectors tested whether providers had completed their Subjective, Objective,
Assessment, Plan, and Education (SOAPE) notes at the required three-day intervals, they
found that providers timely completed SOAPE notes for only 3 of the 10 sampled patients
(30 percent). In addition, provider visits for seven patients ranged from one to eight days late
(MIT 13.003).
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SPECIALTY SERVICES
This indicator focuses on specialist care from the time a
Case Review Rating:
physician completes a request for services or a physician’s order Adequate
for specialist care to the time of receipt of related Compliance Score:
recommendations from specialists. This indicator also evaluates Inadequate
(72.6%)
the providers’ timely review of specialist records and
documentation reflecting the patients’ care plans, including the Overall Rating:
course of care when specialist recommendations were not Adequate
ordered, and whether the results of specialists’ reports are
communicated to the patients. For specialty services denied by the institution, the OIG
determines whether the denials are timely and appropriate, and whether the provider updates the
patient on the plan of care.
In this indicator, the OIG case review and compliance review processes yielded different results,
with the case reviewers assigning an adequate rating and the compliance testing receiving an
inadequate score. Compliance review testing received an inadequate score due to a delay in the
provider’s review of specialty services, delays in denials of requests for specialty services, and a
delay in communicating a denied request for service to the patient. Case review showed
providers reviewed specialty services appropriately, and the delays did not increase the risk of
harm. Likewise, neither the delays in denying referrals nor the communication delays increased
the risk of harm to the patient. The OIG’s internal review process considered the factors leading
to both scores and ultimately determined the overall rating for this indicator was adequate.
Case Review Results
The OIG clinicians reviewed 70 events related to Specialty Services, which included 53 specialty
consultations and procedures, and 10 nursing encounters. In total, eight deficiencies were found
in this category, with three related to access to care, two to specialty report handling, and three to
nursing performance. Four of the eight deficiencies were significant and are explained in detail
below.
Access to Specialty Services
HDSP performed well in access to specialty services, experiencing no problems with accessing
specialists. Specialty services were provided within adequate time frames when the provider
ordered them. One significant deficiency was noted in which the provider failed to order a
specialty follow-up appointment. Two minor deficiencies were found for which HDSP delayed
the provider follow-up to review specialist recommendations.
Nursing Performance
HDSP nursing performance was acceptable for patients returning from offsite specialty
appointments. However, in contrast to the TTA nurses who processed the patients when they
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returned from offsite specialty visits, the nurses who processed the patients who utilized
telemedicine specialty services occasionally failed to inform the provider of the specialist’s
findings and recommendations. In two cases, this resulted in delays in implementing necessary
recommendations such as changes in medication dosage or requests for diagnostic tests.
Provider Performance
HDSP providers made timely and proper referrals for specialty services with the appropriate
priority. Only one significant deficiency was noted in the following case:
• In case 11, the provider did not review a specialty report thoroughly enough to order a
recommended laboratory test and a follow-up appointment with the specialist.
Health Information Management
HDSP’s specialty department performed well in retrieving most specialty reports promptly. The
providers timely reviewed the specialty reports with only two significant exceptions occurring in
the following case:
• In case 15, the patient saw the neurologist, but HDSP did not retrieve and scan the report
until four months later. The provider never did sign the report.
• Also in case 15, the hematologist-oncologist saw the patient, and the report was properly
retrieved. Nonetheless, the provider reviewed the report 24 days later.
Clinician Onsite Inspection
The OIG clinicians discussed the deficiencies with HDSP supervisors of medical records and
nursing. Regarding the nursing deficiencies, HDSP implemented recommendations from offsite
specialists much sooner than those from telemedicine specialists. Staff explained that the TTA
nurses relayed the offsite recommendations directly to the clinic when the patients returned to the
institution. Conversely, telemedicine specialty services nurses did not relay information to the
clinic staff. Referring to the CCHCS policy, they instead presumed that the provider would
review the recommendations when the patient followed up with the provider within 14 days.
The telemedicine nurses explained that, occasionally, the verbal information the specialist
provided differed from that contained in the specialist’s written report. Therefore, the nurses
thought it was better to hold off relaying information until the report was available. The OIG
does not agree with the institution’s intentional delay in transmitting telemedicine specialty
recommendations. Some of the information was time-sensitive, for example, starting medication
administration or ensuring appropriately timely follow-up specialty appointments. Expediting
such instructions was critical for providers to initiate appropriate orders.
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Case Review Conclusion
HDSP performed well with both specialty access and retrieving offsite specialty
recommendations. However, HDSP sometimes introduced unnecessary delays in the
communication of telemedicine specialty recommendations. The overall rating for this indicator
was adequate.
Compliance Testing Results
The institution received a score of 72.6 percent in this indicator, with the following four tests
demonstrating room for improvement:
• Among 20 sampled patients for whom HDSP’s health care management denied a specialty
service, only 12 of them (60 percent) received timely notification of the service denial,
including a provider meeting with the patient within 30 days to discuss alternate treatment
strategies. For two patients, the providers’ follow-up visits occurred 3 and 16 days late. For
six patients, no provider follow-up appointments occurred during which reasons for denials
could be discussed (MIT 14.007).
• When HDSP providers ordered high-priority specialty services for patients, the ordering
provider did not always review the specialty report within the required time frame. While
providers timely reviewed 9 of the 14 sampled specialty reports (64 percent), 4 other reports
were reviewed from one to eight days late, and for one report, the OIG found no medical
record evidence of review (MIT 14.002).
• When patients are approved or scheduled for specialty services at one institution and then
transfer to another, policy requires that the receiving institution schedule and provide these
patients specialty appointments within required time frames. Of the 20 applicable sampled
patients who transferred into HDSP with approved specialty services, 14 of them
(70 percent) received their appointments within the required time frame. Two patients’
services were 12 and 19 days late, and for four remaining patients, OIG inspectors found no
medical record evidence the specialty service was performed (MIT 14.005).
• The institution timely denied providers’ specialty service requests for 14 of 20 patients
sampled (70 percent). Six of the specialty services requests were denied between one and
13 days late (MIT 14.006).
Two tests received scores in the adequate range:
• Providers timely received and reviewed 10 of the 13 sampled routine specialists’ reports
(77 percent). For two patients, providers reviewed the reports seven and eight days late; and
for the final patient, OIG inspectors found no medical record evidence a provider reviewed
the report (MIT 14.004).
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• HDSP provided routine specialty service appointments within required time frames to 12 of
15 patients tested (80 percent). Three patients received their specialty services from one day
to 54 days late (MIT 14.003).
One test earned a score of proficient:
• For 13 of 15 sampled patients (87 percent), their high-priority specialty services’
appointments occurred within 14 calendar days of the provider’s order, but two patients
received their specialty services 6 and 28 days late (MIT 14.001).
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ADMINISTRATIVE OPERATIONS (SECONDARY)
This indicator focuses on the institution’s administrative health
Case Review Rating:
care oversight functions. The OIG evaluates whether the Not Applicable
institution promptly processes patient medical appeals and Compliance Score:
addresses all appealed issues. Inspectors also verify that the Inadequate
(62.0%)
institution follows reporting requirements for adverse/sentinel
events and patient deaths. The OIG verifies that the Emergency Overall Rating:
Medical Response Review Committee (EMRRC) performs Inadequate
required reviews and that staff perform required emergency
response drills. Inspectors also assess whether the Quality Management Committee (QMC)
meets regularly and adequately addresses program performance. For those institutions with
licensed facilities, inspectors also verify that required committee meetings are held. In addition,
the OIG examines whether the institution adequately manages its health care staffing resources
by evaluating whether job performance reviews are completed as required; specified staff
possess current, valid credentials and professional licenses or certifications; nursing staff receive
new employee orientation training and annual competency testing; and clinical and custody staff
have current emergency medical response certifications. The Administrative Operations indicator
is a secondary indicator; therefore, it was not relied on for the institution’s overall score.
Compliance Testing Results
The institution received a score of 62.0 percent in this indicator with several tests demonstrating
room for improvement:
• The OIG inspected records from June 2017 for five nurses to determine whether their
nursing supervisors properly completed monthly performance reviews. OIG inspectors
identified that supervisors had not completed the requisite number of reviews for all five
nurses, resulting in a score of zero in this test (MIT 15.104).
• None of HDSP’s providers had received either timely or properly completed appraisals,
including the following (MIT 15.106):
o Four providers’ evaluations were overdue by 11 to 22 months, and one provider had
no performance appraisals available for review;
o Among the five providers tested, the most recently completed evaluations for two
providers did not include 360-degree evaluations.
• HDSP had hired 23 nurses over the preceding 12-month period. The OIG inspectors
identified two nurses who had received their orientations four weeks late (MIT 15.111).
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Office of the Inspector General State of California
• The OIG inspectors reviewed data received from the institution (which was not validated by
the OIG) to determine whether HDSP timely processed at least 95 percent of its monthly
patient medical appeals during the most recent 12-month period. HDSP was compliant with
only one of the 12 months’ appeals reviewed (8 percent) (MIT 15.001).
• HDSP’s local governing body met quarterly during the four-quarter period ending
March 2017, but only one of the corresponding meeting minutes was sufficiently detailed
and timely approved (25 percent). Three meetings’ minutes were insufficient because they
lacked discussions on adopting local operating procedures as CCHCS policy requires
(MIT 15.006).
• The institution did not meet the emergency response drill requirements for the most recent
quarter for two of its three watches, resulting in a score of 33 percent. More specifically, the
institution’s first- and second-watch drill packages lacked evidence that custody staff
participated in the emergency response drills (MIT 15.101).
• Medical staff reviewed and timely submitted the Initial Inmate Death Report
(CDCR Form 7229A) to CCHCS’ Death Review Unit for two of four cases tested, resulting
in a score of 50 percent. For one death report packet, the death report form was missing the
initials of either the CME or the CEO. For the other death report packet, the institution did
not submit the death report within the required time frame, instead, submitting it one
business day late (MIT 15.103).
One test earned an adequate score:
• The OIG examined 12 of the institution’s Emergency Medical Response Review Committee
(EMRRC) incident packages for emergency medical responses during the prior 12-month
period. Of this dozen, nine of them (75 percent) complied with policy, but the remaining
three packages contained improperly completed checklists (MIT 15.005).
Several tests earned scores in the proficient range:
• HDSP’s QMC met monthly, evaluated program performance, and took action when
management identified areas for improvement opportunities (MIT 15.003).
• The institution took adequate steps to ensure the accuracy of its Dashboard data reporting
(MIT 15.004).
• Based on a sample of ten second-level medical appeals, the institution’s responses addressed
all of the patients’ appealed issues (MIT 15.102).
• All ten sampled nurses were current with their clinical competency validations
(MIT 15.105).
High Desert State Prison, Cycle 5 Medical Inspection Page 60
Office of the Inspector General State of California
• All providers at the institution were current with their professional licenses. Similarly, all
nursing staff and the PIC were current with their professional licenses and certification
requirements (MIT 15.107, 15.109).
• All active-duty providers and nurses were current with their emergency response
certifications (MIT 15.108).
• All pharmacy staff and providers who prescribed controlled substances had current Drug
Enforcement Agency registrations (MIT 15.110).
Non-Scored Results
• The OIG gathered non-scored data regarding the CCHCS Death Review Committee (DRC)
completing its death review reports. Three unexpected (Level 1) deaths occurred during the
OIG’s review period. The DRC was required to complete its death review summary reports
within 60 calendar days from the dates of death and submit these reports to the institution’s
CEO within seven calendar days thereafter. While one death review report was completed
timely, the DRC completed the other two reports 60 and 97 days late, respectively, and
submitted them to HDSP’s CEO one to two days thereafter (MIT 15.998).
• The OIG discusses the institution’s health care staffing resources in the About the Institution
section of this report (MIT 15.999).
High Desert State Prison, Cycle 5 Medical Inspection Page 61
Office of the Inspector General State of California
R
ECOMMENDATIONS
The OIG recommends the following:
• The HDSP chief physician and surgeon (CP&S) or chief medical executive (CME) should
periodically check the electronic health records system (EHRS) message center to ensure
providers promptly review all pertinent results and reports.
• HDSP should designate an onsite physician supervisor who can support mid-level providers,
review their work, and provide appropriate supervision, all of which should lead to
improved mid-level provider performance.
• At the time of the OIG’s onsite inspection, HDSP unnecessarily delayed transmitting
telemedicine specialty recommendations. The institution should send telemedicine specialty
recommendations to the provider immediately, as it already does for offsite specialty
recommendations. By using similar rapid processes for transmitting both types of specialty
recommendations, HDSP can reduce the risk of lapses in care.
High Desert State Prison, Cycle 5 Medical Inspection Page 62
Office of the Inspector General State of California
P -B M
OPULATION ASED ETRICS
The compliance testing and the case reviews give an accurate assessment of how the institution’s
health care systems are functioning with regard to the patients with the highest risk and
utilization. This information is vital to assess the capacity of the institution to provide
sustainable, adequate care. However, one significant limitation of the case review methodology
is that it does not give a clear assessment of how the institution performs for the entire
population. For better insight into this performance, the OIG has turned to population-based
metrics. For comparative purposes, the OIG has selected several Healthcare Effectiveness Data
and Information Set (HEDIS) measures for disease management to gauge the institution’s
effectiveness in outpatient health care, especially chronic disease management.
The Healthcare Effectiveness Data and Information Set is a set of standardized performance
measures developed by the National Committee for Quality Assurance with input from over
300 organizations representing every sector of the nation’s health care industry. It is used by over
90 percent of the nation’s health plans as well as many leading employers and regulators. HEDIS
was designed to ensure that the public (including employers, the Centers for Medicare and
Medicaid Services, and researchers) has the information it needs to accurately compare the
performance of health care plans. Healthcare Effectiveness Data and Information Set data is
often used to produce health plan report cards, analyze quality improvement activities, and create
performance benchmarks.
Methodology
For population-based metrics, the OIG used a subset of HEDIS measures applicable to the
CDCR patient population. Selection of the measures was based on the availability, reliability,
and feasibility of the data required for performing the measurement. The OIG collected data
utilizing various information sources, including the electronic medical record, the Master
Registry (maintained by CCHCS), as well as a random sample of patient records analyzed and
abstracted by trained personnel. Data obtained from the CCHCS Master Registry and Diabetic
Registry was not independently validated by the OIG and is presumed to be accurate. For some
measures, the OIG used the entire population rather than statistically random samples. While the
OIG is not a certified HEDIS compliance auditor, the OIG uses similar methods to ensure that
measures are comparable to those published by other organizations.
Comparison of Population-Based Metrics
For High Desert State Prison, nine HEDIS measures were selected and are listed in the following
HDSP Results Compared to State and National HEDIS Scores table. Multiple health plans
publish their HEDIS performance measures at the state and national levels. The OIG has
provided selected results for several health plans in both categories for comparative purposes.
High Desert State Prison, Cycle 5 Medical Inspection Page 63
Office of the Inspector General State of California
Results of Population-Based Metric Comparison
Comprehensive Diabetes Care
For chronic care management, the OIG chose measures related to the management of diabetes.
Diabetes is the most complex common chronic disease requiring a high level of intervention on
the part of the health care system in order to produce optimal results. HDSP performed well with
its management of diabetes.
When compared statewide, HDSP outperformed Medi-Cal in all five diabetic measures, and the
institution outperformed Kaiser in three of the five diabetic measures. HDSP scored slightly
lower in blood pressure control than Kaiser (North and South), and the institution performed
lower than Kaiser South in eye exams.
When compared nationally, the institution outperformed Medicaid, Commercial Plans, and
Medicare in all five diabetic measures. The institution also outperformed the United States
Department of Veterans Affairs (VA) in three of the four applicable measures, with HDSP
scoring lower in diabetic eye exams.
Immunizations
Comparative data for immunizations was only fully available for the VA and partially available
for Kaiser, commercial plans, Medicaid, and Medicare. With respect to administering influenza
vaccinations to younger adults and older adults, HDSP outperformed all healthcare plans. With
regard to administering pneumococcal vaccines to older adults, HDSP matched Medicare, but
scored lower than the VA.
Cancer Screening
With respect to colorectal cancer screening, HDSP scored higher than commercial plans and
Medicare, and matched Kaiser North. However, the institution scored lower than Kaiser South
and the VA. The 18 percent refusal rate for colorectal cancer screening at the institution
negatively affected the score for this measure.
Summary
HDSP performed well with regard to population-based metrics in comparison to the other health
care plans reviewed. The institution may improve its scores colorectal cancer screenings by
reducing patient refusals through educating patients on the benefits of these preventive services.
High Desert State Prison, Cycle 5 Medical Inspection Page 64
Office of the Inspector General State of California
HDSP Results Compared to State and National HEDIS Scores
California National
HEDIS HEDIS
HDSP HEDIS
HEDIS Kaiser Kaiser HEDIS HEDIS VA
Clinical Measures Com-
Medi-Cal (No. (So. Medicaid Medicare Average
Cycle 5 mercial
20152 CA) CA) 20164 20164 20155
Results1 20164
20163 20163
Comprehensive Diabetes Care
HbA1c Testing (Monitoring) 100% 86% 94% 94% 86% 90% 93% 98%
Poor HbA1c Control (>9.0%)6, 7 16% 39% 20% 23% 45% 34% 27% 19%
HbA1c Control (<8.0%)6 75% 49% 70% 63% 46% 55% 63% -
Blood Pressure Control
76% 63% 83% 83% 59% 60% 62% 74%
(<140/90)6
Eye Exams 73% 53% 68% 81% 53% 54% 69% 89%
Immunizations
Influenza Shots - Adults (18–64) 67% - 56% 57% 39% 48% - 55%
Influenza Shots - Adults (65+) 86% - - - - - 72% 76%
Immunizations: Pneumococcal 71% - - - - - 71% 93%
Cancer Screening
Colorectal Cancer Screening 79% - 79% 82% - 63% 67% 82%
1. Unless otherwise stated, data was collected in August 2017 by reviewing medical records from a sample
of HDSP’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.
2. HEDIS Medi-Cal data was obtained from the California Department of Health Care Services 2015
HEDIS Aggregate Report for Medi-Cal Managed Care.
3. Data was obtained from Kaiser Permanente November 2016 reports for the Northern and Southern
California regions.
4. National HEDIS data for Medicaid, commercial plans, and Medicare was obtained from the 2016 State of
Health Care Quality Report, available on the NCQA website: www.ncqa.org. The results for commercial
plans were based on data received from various health maintenance organizations.
5. The Department of Veterans Affairs (VA) data was obtained from the VA’s website, www.va.gov. For
the Immunizations: Pneumococcal measure only, the data was obtained from the VHA Facility Quality and
Safety Report - Fiscal Year 2012 Data.
6. For this indicator, the entire applicable HDSP population was tested.
7. For this measure only, a lower score is better. For Kaiser, the OIG derived the Poor HbA1c Control
indicator using the reported data for the <9.0% HbA1c control indicator.
High Desert State Prison, Cycle 5 Medical Inspection Page 65
Office of the Inspector General State of California
A A — C T R
PPENDIX OMPLIANCE EST ESULTS
High Desert State Prison
Range of Summary Scores: 58.9% – 81.3%
Indicator Compliance Score (Yes %)
1 – Access to Care 75.5%
2 – Diagnostic Services 58.9%
3 – Emergency Services Not Applicable
4 – Health Information Management (Medical Records) 66.0%
5 – Health Care Environment 76.6%
6 – Inter- and Intra-System Transfers 70.3%
7 – Pharmacy and Medication Management 68.8%
8 – Prenatal and Post-Delivery Services Not Applicable
9 – Preventive Services 81.3%
10 – Quality of Nursing Performance Not Applicable
11 – Quality of Provider Performance Not Applicable
12 – Reception Center Arrivals Not Applicable
13 – Specialized Medical Housing (OHU, CTC, SNF, Hospice) 77.5%
14 – Specialty Services 72.6%
15 – Administrative Operations 62.0%
High Desert State Prison, Cycle 5 Medical Inspection Page 66
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
1 – Access to Care
Number Yes No No Yes % N/A
Chronic care follow-up appointments: Was the patient’s most
recent chronic care visit within the health care guideline’s
1.001 20 5 25 80.0% 0
maximum allowable interval or within the ordered time frame,
whichever is shorter?
For endorsed patients received from another CDCR institution: If
1.002 the nurse referred the patient to a provider during the initial health 9 16 25 36.0% 0
screening, was the patient seen within the required time frame?
Clinical appointments: Did a registered nurse review the patient’s
1.003 29 1 30 96.7% 0
request for service the same day it was received?
Clinical appointments: Did the registered nurse complete a face-
1.004 to-face visit within one business day after the CDCR Form 7362 30 0 30 100.0% 0
was reviewed?
Clinical appointments: If the registered nurse determined a
referral to a primary care provider was necessary, was the patient
1.005 14 9 23 60.9% 7
seen within the maximum allowable time or the ordered time
frame, whichever is the shorter?
Sick call follow-up appointments: If the primary care provider
1.006 ordered a follow-up sick call appointment, did it take place within 7 2 9 77.8% 21
the time frame specified?
Upon the patient’s discharge from the community hospital: Did
1.007 the patient receive a follow-up appointment within the required 5 3 8 62.5% 0
time frame?
Specialty service follow-up appointments: Do specialty service
1.008 primary care physician follow-up visits occur within required time 17 9 26 65.4% 4
frames?
Clinical appointments: Do patients have a standardized process to
1.101 6 0 6 100.0% 0
obtain and submit health care services request forms?
Overall percentage: 75.5%
High Desert State Prison, Cycle 5 Medical Inspection Page 67
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
2 – Diagnostic Services
Number Yes No No Yes % N/A
Radiology: Was the radiology service provided within the time
2.001 10 0 10 100.0% 0
frame specified in the provider’s order?
Radiology: Did the primary care provider review and initial the
2.002 3 7 10 30.0% 0
diagnostic report within specified time frames?
Radiology: Did the primary care provider communicate the results
2.003 3 7 10 30.0% 0
of the diagnostic study to the patient within specified time frames?
Laboratory: Was the laboratory service provided within the time
2.004 10 0 10 100.0% 0
frame specified in the provider’s order?
Laboratory: Did the primary care provider review and initial the
2.005 6 4 10 60.0% 0
diagnostic report within specified time frames?
Laboratory: Did the primary care provider communicate the
2.006 results of the diagnostic study to the patient within specified time 3 7 10 30.0% 0
frames?
Pathology: Did the institution receive the final diagnostic report
2.007 9 1 10 90.0% 0
within the required time frames?
Pathology: Did the primary care provider review and initial the
2.008 5 5 10 50.0% 0
diagnostic report within specified time frames?
Pathology: Did the primary care provider communicate the results
2.009 4 6 10 40.0% 0
of the diagnostic study to the patient within specified time frames?
Overall percentage: 58.9%
3 – Emergency Services
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
High Desert State Prison, Cycle 5 Medical Inspection Page 68
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
4 – Health Information Management
Number Yes No No Yes % N/A
Are non-dictated healthcare documents (provider progress notes)
4.001 9 4 13 69.2% 0
scanned within 3 calendar days of the patient encounter date?
Are dictated/transcribed documents scanned into the patient’s
4.002 electronic health record within five calendar days of the encounter Not Applicable
date?
Are High-Priority specialty notes (either a Form 7243 or other
4.003 scanned consulting report) scanned within the required time 13 7 20 65.0% 0
frame?
Are community hospital discharge documents scanned into the
4.004 patient’s electronic health record within three calendar days of 6 2 8 75.0% 0
hospital discharge?
Are medication administration records (MARs) scanned into the
4.005 Not Applicable
patient’s electronic health record within the required time frames?
During the inspection, were medical records properly scanned,
4.006 14 10 24 58.3% 0
labeled, and included in the correct patients’ files?
For patients discharged from a community hospital: Did the
preliminary hospital discharge report include key elements and
4.007 5 3 8 62.5% 0
did a primary care provider review the report within three
calendar days of discharge?
Overall percentage: 66.0%
High Desert State Prison, Cycle 5 Medical Inspection Page 69
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
5 – Health Care Environment
Number Yes No No Yes % N/A
Are clinical health care areas appropriately disinfected, cleaned
5.101 12 0 12 100.0% 0
and sanitary?
Do clinical health care areas ensure that reusable invasive and
5.102 non-invasive medical equipment is properly sterilized or 9 2 11 81.8% 1
disinfected as warranted?
Do clinical health care areas contain operable sinks and sufficient
5.103 11 1 12 91.7% 0
quantities of hygiene supplies?
Does clinical health care staff adhere to universal hand hygiene
5.104 6 5 11 54.6% 1
precautions?
Do clinical health care areas control exposure to blood-borne
5.105 11 1 12 91.7% 0
pathogens and contaminated waste?
Warehouse, Conex and other non-clinic storage areas: Does the
5.106 medical supply management process adequately support the needs 1 0 1 100.0% 0
of the medical health care program?
Does each clinic follow adequate protocols for managing and
5.107 6 6 12 50.0% 0
storing bulk medical supplies?
Do clinic common areas and exam rooms have essential core
5.108 9 3 12 75.0% 0
medical equipment and supplies?
Do clinic common areas have an adequate environment conducive
5.109 9 3 12 75.0% 0
to providing medical services?
Do clinic exam rooms have an adequate environment conducive
5.110 8 3 11 72.7% 1
to providing medical services?
Emergency response bags: Are TTA and clinic emergency
5.111 medical response bags inspected daily and inventoried monthly, 4 4 8 50.0% 4
and do they contain essential items?
Overall percentage: 76.6%
High Desert State Prison, Cycle 5 Medical Inspection Page 70
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
6 – Inter- and Intra-System Transfers
Number Yes No No Yes % N/A
For endorsed patients received from another CDCR institution or
COCF: Did nursing staff complete the initial health screening and
6.001 25 0 25 100.0% 0
answer all screening questions on the same day the patient arrived
at the institution?
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
disposition section of the health screening form; refer the patient
6.002 25 0 25 100.0% 0
to the TTA, if TB signs and symptoms were present; and sign and
date the form on the same day staff completed the health
screening?
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon
6.003 13 4 17 76.5% 8
arrival, were medications administered or delivered without
interruption?
For patients transferred out of the facility: Were scheduled
6.004 specialty service appointments identified on the patient’s health 15 5 20 75.0% 0
care transfer information form?
For patients transferred out of the facility: Do medication transfer
6.101 packages include required medications along with the 0 9 9 0.0% 0
corresponding transfer packet required documents?
Overall percentage: 70.3%
High Desert State Prison, Cycle 5 Medical Inspection Page 71
Office of the Inspector General State of California
Scored Answers
7 – Pharmacy and Medication Yes
Reference +
Management
Number Yes No No Yes % N/A
Did the patient receive all chronic care medications within the
7.001 required time frames or did the institution follow departmental 6 10 16 37.5% 9
policy for refusals or no-shows?
Did health care staff administer, make available, or deliver new
7.002 order prescription medications to the patient within the required 20 5 25 80.0% 0
time frames?
Upon the patient’s discharge from a community hospital: Were all
7.003 ordered medications administered, made available, or delivered to 6 2 8 75.0% 0
the patient within required time frames?
For patients received from a county jail: Were all medications
ordered by the institution’s reception center provider
7.004 Not Applicable
administered, made available, or delivered to the patient within
the required time frames?
Upon the patient’s transfer from one housing unit to another:
7.005 21 4 25 84.0% 0
Were medications continued without interruption?
For patients en route who lay over at the institution: If the
7.006 temporarily housed patient had an existing medication order, were Not Applicable
medications administered or delivered without interruption?
All clinical and medication line storage areas for narcotic
7.101 medications: Does the Institution employ strong medication 2 5 7 28.6% 5
security over narcotic medications assigned to its clinical areas?
All clinical and medication line storage areas for non-narcotic
medications: Does the Institution properly store non-narcotic
7.102 11 1 12 91.7% 0
medications that do not require refrigeration in assigned clinical
areas?
All clinical and medication line storage areas for non-narcotic
7.103 medications: Does the institution properly store non-narcotic 8 1 9 88.9% 3
medications that require refrigeration in assigned clinical areas?
Medication preparation and administration areas: Do nursing staff
employ and follow hand hygiene contamination control protocols
7.104 4 2 6 66.7% 6
during medication preparation and medication administration
processes?
Medication preparation and administration areas: Does the
7.105 institution employ appropriate administrative controls and 6 0 6 100.0% 6
protocols when preparing medications for patients?
Medication preparation and administration areas: Does the
7.106 Institution employ appropriate administrative controls and 0 6 6 0.0% 6
protocols when distributing medications to patients?
Pharmacy: Does the institution employ and follow general
7.107 security, organization, and cleanliness management protocols in 1 0 1 100.0% 0
its main and satellite pharmacies?
High Desert State Prison, Cycle 5 Medical Inspection Page 72
Office of the Inspector General State of California
Scored Answers
7 – Pharmacy and Medication Yes
Reference +
Management
Number Yes No No Yes % N/A
Pharmacy: Does the institution’s pharmacy properly store non-
7.108 1 0 1 100.0% 0
refrigerated medications?
Pharmacy: Does the institution’s pharmacy properly store
7.109 1 0 1 100.0% 0
refrigerated or frozen medications?
Pharmacy: Does the institution’s pharmacy properly account for
7.110 0 1 1 0.0% 0
narcotic medications?
Does the institution follow key medication error reporting
7.111 20 5 25 80.0% 0
protocols?
Overall percentage: 68.8%
8 – Prenatal and Post-Delivery Services
The institution had no female patients, so this indicator was not applicable.
High Desert State Prison, Cycle 5 Medical Inspection Page 73
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
9 – Preventive Services
Number Yes No No Yes % N/A
Patients prescribed TB medication: Did the institution administer
9.001 5 4 9 55.6% 0
the medication to the patient as prescribed?
Patients prescribed TB medication: Did the institution monitor the
9.002 patient monthly for the most recent three months he or she was on 7 2 9 77.8% 0
the medication?
Annual TB Screening: Was the patient screened for TB within the
9.003 28 2 30 93.3% 0
last year?
Were all patients offered an influenza vaccination for the most
9.004 25 0 25 100.0% 0
recent influenza season?
All patients from the age of 50 - 75: Was the patient offered
9.005 24 1 25 96.0% 0
colorectal cancer screening?
Female patients from the age of 50 through the age of 74: Was the
9.006 Not Applicable
patient offered a mammogram in compliance with policy?
Female patients from the age of 21 through the age of 65: Was
9.007 Not Applicable
patient offered a pap smear in compliance with policy?
Are required immunizations being offered for chronic care
9.008 13 7 20 65.0% 5
patients?
Are patients at the highest risk of coccidioidomycosis (valley
9.009 Not Applicable
fever) infection transferred out of the facility in a timely manner?
Overall percentage: 81.3%
10 – Quality of Nursing Performance
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
11 – Quality of Provider Performance
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
High Desert State Prison, Cycle 5 Medical Inspection Page 74
Office of the Inspector General State of California
12 – Reception Center Arrivals
The institution had no reception center, so this indicator was not applicable.
Scored Answers
Yes
Reference +
13 – Specialized Medical Housing
Number Yes No No Yes % N/A
For OHU, CTC, and SNF: Did the registered nurse complete an
13.001 initial assessment of the patient on the day of admission, or within 9 1 10 90.0% 0
eight hours of admission to CMF’s Hospice?
For CTC and SNF only: Was a written history and physical
13.002 9 1 10 90.0% 0
examination completed within the required time frame?
For OHU, CTC, SNF, and Hospice: Did the primary care provider
complete the Subjective, Objective, Assessment, Plan, and
13.003 3 7 10 30.0% 0
Education (SOAPE) notes on the patient at the minimum intervals
required for the type of facility where the patient was treated?
For OHU and CTC only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
13.101 1 0 1 100.0% 0
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells?
Overall percentage: 77.5%
High Desert State Prison, Cycle 5 Medical Inspection Page 75
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
14 – Specialty Services
Number Yes No No Yes % N/A
Did the patient receive the high priority specialty service within
14.001 14 calendar days of the primary care provider order or the 13 2 15 86.7% 0
Physician Request for Service?
Did the primary care provider review the high priority specialty
14.002 9 5 14 64.3% 1
service consultant report within the required time frame?
Did the patient receive the routine specialty service within 90
14.003 calendar days of the primary care provider order or Physician 12 3 15 80.0% 0
Request for Service?
Did the primary care provider review the routine specialty service
14.004 10 3 13 76.9% 2
consultant report within the required time frame?
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at
14.005 14 6 20 70.0% 0
the sending institution, was the appointment scheduled at the
receiving institution within the required time frames?
Did the institution deny the primary care provider request for
14.006 14 6 20 70.0% 0
specialty services within required time frames?
Following the denial of a request for specialty services, was the
14.007 12 8 20 60.0% 0
patient informed of the denial within the required time frame?
Overall percentage: 72.6%
High Desert State Prison, Cycle 5 Medical Inspection Page 76
Office of the Inspector General State of California
Scored Answers
Yes
Reference
15 – Administrative Operations +
Number Yes No No Yes % N/A
Did the institution promptly process inmate medical appeals
15.001 1 11 12 8.3% 0
during the most recent 12 months?
Does the institution follow adverse / sentinel event reporting
15.002 Not Applicable
requirements?
Did the institution Quality Management Committee (QMC) meet
at least monthly to evaluate program performance, and did the
15.003 6 0 6 100.0% 0
QMC take action when improvement opportunities were
identified?
Did the institution’s Quality Management Committee (QMC) or
15.004 other forum take steps to ensure the accuracy of its Dashboard 1 0 1 100.0% 0
data reporting?
Does the Emergency Medical Response Review Committee
15.005 perform timely incident package reviews that include the use of 9 3 12 75.0% 0
required review documents?
For institutions with licensed care facilities: Does the Local
Governing Body (LGB), or its equivalent, meet quarterly and
15.006 1 3 4 25.0% 0
exercise its overall responsibilities for the quality management of
patient health care?
Did the institution complete a medical emergency response drill
15.101 for each watch and include participation of health care and 1 2 3 33.3% 0
custody staff during the most recent full quarter?
Did the institution’s second level medical appeal response address
15.102 10 0 10 100.0% 0
all of the patient’s appealed issues?
Did the institution’s medical staff review and submit the initial
15.103 2 2 4 50.0% 0
inmate death report to the Death Review Unit in a timely manner?
Does the institution’s Supervising Registered Nurse conduct
15.104 0 5 5 0.0% 0
periodic reviews of nursing staff?
Are nursing staff who administer medications current on their
15.105 10 0 10 100.0% 0
clinical competency validation?
15.106 Are structured clinical performance appraisals completed timely? 0 5 5 0.0% 0
15.107 Do all providers maintain a current medical license? 5 0 5 100.0% 0
Are staff current with required medical emergency response
15.108 2 0 2 100.0% 1
certifications?
Are nursing staff and the Pharmacist-in-Charge current with their
professional licenses and certifications, and is the pharmacy
15.109 6 0 6 100.0% 1
licensed as a correctional pharmacy by the California State Board
of Pharmacy?
High Desert State Prison, Cycle 5 Medical Inspection Page 77
Office of the Inspector General State of California
Scored Answers
Yes
Reference
15 – Administrative Operations +
Number Yes No No Yes % N/A
Do the institution’s pharmacy and authorized providers who
15.110 prescribe controlled substances maintain current Drug 1 0 1 100.0% 0
Enforcement Agency (DEA) registrations?
15.111 Are nursing staff current with required new employee orientation? 0 1 1 0.0% 0
Overall percentage: 62.0%
High Desert State Prison, Cycle 5 Medical Inspection Page 78
Office of the Inspector General State of California
A B — C D
PPENDIX LINICAL ATA
Table B-1: HDSP Sample Sets
Sample Set Total
Anticoagulation 1
CTC/OHU 2
Death Review/Sentinel Events 2
Diabetes 5
Emergency Services – CPR 1
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 4
Intra-System Transfers In 3
Intra-System Transfers Out 3
RN Sick Call 18
Specialty Services 2
47
High Desert State Prison, Cycle 5 Medical Inspection Page 79
Office of the Inspector General State of California
Table B-2: HDSP Chronic Care Diagnoses
Diagnosis Total
Anemia 1
Anticoagulation 1
Arthritis/Degenerative Joint Disease 1
Asthma 8
COPD 6
Cardiovascular Disease 6
Chronic Kidney Disease 2
Chronic Pain 15
Cirrhosis/End-Stage Liver Disease 1
Coccidioidomycosis 1
Deep Venous Thrombosis/Pulmonary Embolism 2
Diabetes 13
Gastroesophageal Reflux Disease 5
Hepatitis C 13
Hyperlipidemia 14
Hypertension 22
Mental Health 8
Migraine Headaches 1
Seizure Disorder 5
Sleep Apnea 4
Thyroid Disease 2
131
High Desert State Prison, Cycle 5 Medical Inspection Page 80
Office of the Inspector General State of California
Table B-3: HDSP Event – Program
Diagnosis Total
Diagnostic Services 83
Emergency Care 54
Hospitalization 28
Intra-System Transfers In 10
Intra-System Transfers Out 6
Not Specified 1
Outpatient Care 415
Specialized Medical Housing 77
Specialty Services 72
746
High Desert State Prison, Cycle 5 Medical Inspection Page 81
Office of the Inspector General State of California
Table B-4: HDSP Review Sample Summary
Total
MD Reviews Detailed 20
MD Reviews Focused 1
RN Reviews Detailed 12
RN Reviews Focused 27
Total Reviews 60
Total Unique Cases 47
Overlapping Reviews (MD & RN) 13
High Desert State Prison, Cycle 5 Medical Inspection Page 82
Office of the Inspector General State of California
A C — C S M
PPENDIX OMPLIANCE AMPLING ETHODOLOGY
High Desert State Prison
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Access to Care
MIT 1.001 Chronic Care Patients Master Registry • Chronic care conditions (at least one condition per
patient—any risk level)
(25) • Randomize
MIT 1.002 Nursing Referrals OIG Q: 6.001 • See Intra-System Transfers
(25)
MITs 1.003–006 Nursing Sick Call MedSATS • Clinic (each clinic tested)
(5 per clinic) • Appointment date (2–9 months)
(30) • Randomize
MIT 1.007 Returns from OIG Q: 4.007 • See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(8)
MIT 1.008 Specialty Services OIG Q: 14.001 & • See Specialty Services
Follow-up 14.003
(30)
MIT 1.101 Availability of Health OIG onsite • Randomly select one housing unit from each yard
Care Services review
Request Forms
(6)
Diagnostic Services
MITs 2.001–003 Radiology Radiology Logs • Appointment date (90 days–9 months)
• Randomize
(10) • Abnormal
MITs 2.004–006 Laboratory Quest • Appt. date (90 days–9 months)
• Order name (CBC or CMPs only)
• Randomize
(10) • Abnormal
MITs 2.007–009 Pathology InterQual • Appt. date (90 days–9 months)
• Service (pathology related)
(10) • Randomize
High Desert State Prison, Cycle 5 Medical Inspection Page 83
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Timely Scanning OIG Qs: 1.001, • Non-dictated documents
(13) 1.002, & 1.004 • 1st 10 IPs MIT 1.001, 1st 5 IPs MITs 1.002, 1.004
MIT 4.002 OIG Q: 1.001 • Dictated documents
(0) • First 20 IPs selected
MIT 4.003 OIG Qs: 14.002 • Specialty documents
(20) & 14.004 • First 10 IPs for each question
MIT 4.004 OIG Q: 4.007 • Community hospital discharge documents
(8) • First 20 IPs selected
MIT 4.005 OIG Q: 7.001 • MARs
(0) • First 20 IPs selected
MIT 4.006 Documents for • Any misfiled or mislabeled document identified
(10) any tested inmate during OIG compliance review (24 or more = No)
MIT 4.007 Returns From Inpatient claims • Date (2–8 months)
Community Hospital data • Most recent 6 months provided (within date range)
• Rx count
• Discharge date
• Randomize (each month individually)
• First 5 patients from each of the 6 months (if not 5
in a month, supplement from another, as needed)
(8)
Health Care Environment
MIT 5.101–105 Clinical Areas OIG inspector • Identify and inspect all onsite clinical areas.
MIT 5.107–111 (12) onsite review
Inter- and Intra-System Transfers
MIT 6.001–003 Intra-System SOMS • Arrival date (3–9 months)
Transfers • Arrived from (another CDCR facility)
• Rx count
• Randomize
(25)
MIT 6.004 Specialty Services MedSATS • Date of transfer (3–9 months)
Send-Outs • Randomize
(20)
MIT 6.101 Transfers Out OIG inspector • R&R IP transfers with medication
(9) onsite review
High Desert State Prison, Cycle 5 Medical Inspection Page 84
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care OIG Q: 1.001 See Access to Care
Medication • At least one condition per patient—any risk level
• Randomize
(25)
MIT 7.002 New Medication Master Registry • Rx count
Orders • Randomize
(25) • Ensure no duplication of IPs tested in MIT 7.001
MIT 7.003 Returns from OIG Q: 4.007 • See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(8)
MIT 7.004 RC Arrivals – OIG Q: 12.001 • See Reception Center Arrivals
Medication Orders
(N/A at this
institution)
MIT 7.005 Intra-Facility Moves MAPIP transfer • Date of transfer (2–8 months)
data • To location/from location (yard to yard and
to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
(25)
• Randomize
MIT 7.006 En Route SOMS • Date of transfer (2–8 months)
• Sending institution (another CDCR facility)
• Randomize
(0) • NA/DOT meds
MITs 7.101–103 Medication Storage OIG inspector • Identify and inspect clinical & med line areas that
Areas onsite review store medications
(varies by test)
MITs 7.104–106 Medication OIG inspector • Identify and inspect onsite clinical areas that
Preparation and onsite review prepare and administer medications
Administration Areas
(varies by test)
MITs 7.107–110 Pharmacy OIG inspector • Identify & inspect all onsite pharmacies
(1) onsite review
MIT 7.111 Medication Error Monthly • All monthly statistic reports with Level 4 or higher
Reporting medication error • Select a total of 5 months
(25) reports
MIT 7.999 Isolation Unit KOP Onsite active • KOP rescue inhalers & nitroglycerin medications
Medications medication for IPs housed in isolation units
(10) listing
Prenatal and Post-Delivery Services
MIT 8.001–007 Recent Deliveries OB Roster • Delivery date (2–12 months)
(N/A at this • Most recent deliveries (within date range)
institution)
Pregnant Arrivals OB Roster • Arrival date (2–12 months)
(N/A at this • Earliest arrivals (within date range)
institution)
High Desert State Prison, Cycle 5 Medical Inspection Page 85
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Preventive Services
MITs 9.001–002 TB Medications Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months or 12 weeks)
(9) • Randomize
MIT 9.003 TB Evaluation, SOMS • Arrival date (at least 1 year prior to inspection)
Annual Screening • Birth Month
(30) • Randomize
MIT 9.004 Influenza SOMS • Arrival date (at least 1 year prior to inspection)
Vaccinations • Randomize
(25) • Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer SOMS • Arrival date (at least 1 year prior to inspection)
Screening • Date of birth (51 or older)
(25) • Randomize
MIT 9.006 Mammogram SOMS • Arrival date (at least 2 yrs prior to inspection)
(N/A at this • Date of birth (age 52–74)
institution) • Randomize
MIT 9.007 Pap Smear SOMS • Arrival date (at least three yrs prior to inspection)
(N/A at this • Date of birth (age 24–53)
institution) • Randomize
MIT 9.008 Chronic Care OIG Q: 1.001 • Chronic care conditions (at least 1 condition per
Vaccinations IP—any risk level)
• Randomize
(25) • Condition must require vaccination(s)
MIT 9.009 Valley Fever Cocci transfer • Reports from past 2–8 months
(number will vary) status report • Institution
(N/A at this • Ineligibility date (60 days prior to inspection date)
institution) • All
High Desert State Prison, Cycle 5 Medical Inspection Page 86
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Reception Center Arrivals
MITs 12.001–008 RC SOMS • Arrival date (2–8 months)
(N/A at this • Arrived from (county jail, return from parole, etc.)
institution) • Randomize
Specialized Medical Housing
MITs 13.001–004 CTC CADDIS • Admit date (1–6 months)
• Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
(10) • Randomize
MIT 13.101 Call Buttons OIG inspector • Review by location
CTC onsite review
(all)
Specialty Services
MITs 14.001–002 High-Priority MedSATS • Approval date (3–9 months)
(15) • Randomize
MITs 14.003–004 Routine MedSATS • Approval date (3–9 months)
• Remove optometry, physical therapy or podiatry
(15) • Randomize
MIT 14.005 Specialty Services MedSATS • Arrived from (other CDCR institution)
Arrivals • Date of transfer (3–9 months)
(20) • Randomize
MIT 14.006–007 Denials InterQual • Review date (3–9 months)
(16) • Randomize
IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
(4) • Randomize
High Desert State Prison, Cycle 5 Medical Inspection Page 87
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Administrative Operations
MIT 15.001 Medical Appeals Monthly medical • Medical appeals (12 months)
(all) appeals reports
MIT 15.002 Adverse/Sentinel Adverse/sentinel • Adverse/sentinel events (2–8 months)
Events events report
(0)
MITs 15.003–004 QMC Meetings Quality • Meeting minutes (12 months)
Management
Committee
(6) meeting minutes
MIT 15.005 EMRRC EMRRC meeting • Monthly meeting minutes (6 months)
(12) minutes
MIT 15.006 LGB LGB meeting • Quarterly meeting minutes (12 months)
(4) minutes
MIT 15.101 Medical Emergency Onsite summary • Most recent full quarter
Response Drills reports & • Each watch
documentation
(3) for ER drills
MIT 15.102 2nd Level Medical Onsite list of • Medical appeals denied (6 months)
Appeals appeals/closed
(10) appeals files
MIT 15.103 Death Reports Institution-list of • Most recent 10 deaths
deaths in prior 12 • Initial death reports
(4) months
MIT 15.104 RN Review Onsite supervisor • RNs who worked in clinic or emergency setting
Evaluations periodic RN six or more days in sampled month
reviews • Randomize
(5)
MIT 15.105 Nursing Staff Onsite nursing • On duty one or more years
Validations education files • Nurse administers medications
(10) • Randomize
MIT 15.106 Provider Annual Onsite • All required performance evaluation documents
Evaluation Packets provider
(5) evaluation files
MIT 15.107 Provider licenses Current provider • Review all
listing (at start of
(5) inspection)
MIT 15.108 Medical Emergency Onsite • All staff
Response certification o Providers (ACLS)
Certifications tracking logs o Nursing (BLS/CPR)
(all) • Custody (CPR/BLS)
MIT 15.109 Nursing staff and Onsite tracking • All required licenses and certifications
Pharmacist in system, logs, or
Charge Professional employee files
Licenses and
Certifications
(all)
High Desert State Prison, Cycle 5 Medical Inspection Page 88
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Administrative Operations
MIT 15.110 Pharmacy and Onsite listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
(all) document
MIT 15.111 Nursing Staff New Nursing staff • New employees (hired within last 12 months)
Employee training logs •
Orientations
(all)
MIT 15.998 Death Review OIG summary log • Between 35 business days & 12 months prior
Committee - deaths • CCHCS death reviews
(4)
High Desert State Prison, Cycle 5 Medical Inspection Page 89
Office of the Inspector General State of California
C C
ALIFORNIA ORRECTIONAL
H C S ’
EALTH ARE ERVICES
R
ESPONSE
High Desert State Prison, Cycle 5 Medical Inspection Page 90
Office of the Inspector General State of California