OIG
Ironwood State Prison Cycle 7 Medical Inspection Report
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Cycle 7, Ironwood State Prison | iii
Contents
Illustrations iv
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 6
Institution-Specific Metrics 6
Population-Based Metrics 9
HEDIS Results 9
Recommendations 12
Indicators 14
Access to Care 14
Diagnostic Services 20
Emergency Services 25
Health Information Management 30
Health Care Environment 36
Transfers 42
Medication Management 49
Preventive Services 57
Nursing Performance 60
Provider Performance 65
Specialized Medical Housing 70
Specialty Services 75
Administrative Operations 81
Appendix A: Methodology 86
Case Reviews 87
Compliance Testing 90
Indicator Ratings and the Overall Medical Quality Rating 91
Appendix B: Case Review Data 92
Appendix C: Compliance Sampling Methodology 96
California Correctional Health Care Services’ Response 104
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | iv
Illustrations
Tables
1. ISP Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. ISP Master Registry Data as of December 2024 7
3. ISP Health Care Staffing Resources as of December 2024 8
4. ISP Results Compared With State HEDIS Scores 11
5. Access to Care 17
6. Other Tests Related to Access to Care 18
7. Diagnostic Services 23
8. Health Information Management 33
9. Other Tests Related to Health Information Management 34
10. Health Care Environment 40
11. Transfers 46
12. Other Tests Related to Transfers 47
13. Medication Management 54
14. Other Tests Related to Medication Management 55
15. Preventive Services 58
16. Specialized Medical Housing 73
17. Specialty Services 78
18. Other Tests Related to Specialty Services 79
19. Administrative Operations 83
A–1. Case Review Definitions 87
B–1. ISP Case Review Sample Sets 92
B–2. ISP Case Review Chronic Care Diagnoses 93
B–3. ISP Case Review Events by Program 94
B–4. ISP Case Review Sample Summary 94
Figures
A–1. Inspection Indicator Review Distribution for ISP 86
A–2. Case Review Testing 89
A–3. Compliance Sampling Methodology 90
Photographs
1. Patient Waiting Area 36
2. Patient Waiting Area 37
3. Compromised Sterile Medical Supply Packaging 37
4. Expired Medical Supply Dated October 31, 2024 38
5. Expired Medical Supply Dated May 30, 2024 38
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care the department provides to
its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 2
As we did during Cycle 6, our office continues to inspect both those institutions
remaining under federal receivership and those delegated back to the department. There
is no difference in the standards used for assessing a delegated institution versus an
institution not yet delegated. At the time of the Cycle 7 inspection of Ironwood State
Prison (ISP), the institution had been delegated back to the department by the receiver.
We completed our seventh inspection of the institution, and this report presents our
assessment of the health care provided at this institution during the inspection period
from June 2024 to November 2024.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between January 2024 and June 2024.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 3
Summary: Ratings and Scores
We completed the Cycle 7 inspection of ISP in May 2025. OIG inspectors monitored the
institution’s delivery of medical care that occurred between June 2024 and November 2024.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at ISP adequate. quality at ISP adequate.
OIG case review clinicians (a team of physicians and nurse consultants) reviewed 47
cases, which contained 747 patient-related events. They performed quality control
reviews; their subsequent collective deliberations ensured consistency, accuracy, and
thoroughness. Our OIG clinicians acknowledged institutional structures that catch and
resolve mistakes, which may occur throughout the delivery of care. After examining the
medical records, our clinicians completed a follow-up on-site inspection in May 2025 to
verify their initial findings. The OIG physicians rated the quality of care for 20
comprehensive case reviews. Of these 20 cases, our physicians rated 18 adequate, and two
inadequate.
To test the institution’s policy compliance, our compliance inspectors (a team of
registered nurses) monitored the institution’s compliance with its medical policies by
answering a standardized set of questions that measure specific elements of health care
delivery. Our compliance inspectors examined 363 patient records and 1,080 data points
and used the data to answer 89 policy questions. In addition, we observed ISP’s processes
during an on-site inspection in January 2025.
The OIG then considered the results from both case review and compliance testing, and
drew overall conclusions, which we report in 13 health care indicators.5
5 The indicators for Reception Center and Prenatal and Postpartum Care did not apply to ISP.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 4
We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. ISP Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 5
Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies can be
minor or significant, depending on the severity of the deficiency. An adverse event occurs
when the deficiency caused harm to the patient. All major health care organizations
identify and track adverse events. We identify deficiencies and adverse events to
highlight concerns regarding the provision of care and for the benefit of the institution’s
quality improvement program to provide an impetus for improvement.6
The OIG found no adverse events at ISP during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 10 of the 13
indicators applicable to ISP. Of these 10 indicators, OIG clinicians rated two proficient
and eight adequate. The OIG physicians also rated the overall adequacy of care for each
of the 20 detailed case reviews they conducted. Of these 20 cases, 18 were adequate and
two were inadequate. In the 747 events reviewed, we identified 95 deficiencies, 17 of
which the OIG clinicians considered to be of such magnitude that, if left unaddressed,
would likely contribute to patient harm.
Our clinicians found the following strengths at ISP:
• Staff performed excellently with access to care by timely offering and
completing appointments for patients.
• Staff performed very well in completing specialty services. Staff also retrieved
and scanned all specialty service reports timely.
• Nurses generally performed good assessments, interventions, and
documentation.
• Nurses documented medication administration very well.
Our clinicians found the following weaknesses at ISP:
• Providers needed improvement in communicating diagnostic test results to
patients with complete patient test result notification letters.
• Nurses needed improvement in performing complete assessments and in
informing providers of significant abnormal findings.
• Staff did not always complete discharge summaries when patients were
discharged from the outpatient housing unit.
6 For a further discussion of an adverse event, see Table A–1.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 6
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable to ISP. Of these 10
indicators, our compliance inspectors rated four proficient, three adequate, and three
inadequate. We solely tested policy compliance in Health Care Environment, Preventive
Services, and Administrative Operations as these indicators do not have a case review
component.
ISP showed a high rate of policy compliance in the following areas:
• Nursing staff received and reviewed health care services request forms and
performed face-to-face evaluations timely. In addition, ISP housing units
contained sufficient supplies of health care request forms.
• Providers timely reviewed radiology, laboratory, and pathology results.
• The institution’s medical staff usually timely scanned nondictated progress
notes, initial health care screening forms, community hospital discharge
reports, and requests for health care services into patients’ electronic medical
records.
• ISP nursing staff performed excellently with providing TB medications to
patients. The institution performed well in offering immunizations and in
providing preventive services for patients, such as influenza vaccinations,
annual testing for tuberculosis (TB), and colorectal cancer screenings.
ISP revealed a low rate of policy compliance in the following areas:
• Patients did not receive their prescribed chronic care medications, hospital
discharge medications, and newly prescribed medications within the
specified time frames.
• Clinical staff did not consistently follow universal hand hygiene precautions
before or after patient encounters.
• Nurses did not regularly inspect emergency medical response bags.
Institution-Specific Metrics
Ironwood State Prison (ISP) is located in Blythe, in eastern Riverside County. The
institution houses minimum-, medium-, and close-custody patients. Patients are seen in
the receiving and release area (R&R) upon arrival to ISP. ISP has multiple medical clinics,
where staff handle requests for routine medical services. ISP treats patients needing
urgent or emergent care in its triage and treatment area (TTA), and those requiring
additional daily care or accommodations in its outpatient housing unit (OHU). The
institution also provides specialty services in a specialty clinic. ISP has been designated a
basic care prison. Basic institutions are located in rural areas, away from tertiary care
centers and specialty care providers whose services would likely be used by higher-risk
patients. Basic institutions can provide limited specialty medical services and
consultation for a generally healthy patient population.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 7
As of August 22, 2025, the department reported on its public tracker 73 percent of ISP’s
incarcerated population was fully vaccinated for COVID-19 while 68 percent of ISP’s staff
was fully vaccinated for COVID-19.7
On February 27, 2024, the Health Care Services Master Registry showed ISP had a total
population of 2,978. A breakdown of the medical risk level of the ISP population as
determined by the department is set forth in Table 2 below.8
Table 2. ISP Master Registry Data as of December 2024
Medical Risk Level Number of Patients Percentage*
High 1 49 1.6%
High 2 171 5.7%
Medium 489 16.4%
Low 2,269 76.2%
Total 2,978 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from
the CCHCS Master Registry dated 2-27-24.
7 For more information, see the department’s statistics on its website page titled Population COVID-19
Tracking.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 8
According to staffing data the OIG obtained from California Correctional Health Care
Services (CCHCS), as identified in Table 3 below, ISP had one vacant executive leadership
position, one vacant primary care provider position, 0.2 nursing supervisor vacancy, and
8.7 nursing staff vacancies.
Table 3. ISP Health Care Staffing Resources as of December 2024
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 4.0 7.0 11.7 75.7 98.4
Filled by Civil Service 3.0 2.0 11.5 67.0 83.5
Vacant 1.0 1.0 0.2 8.7 10.9
Percentage Filled by Civil Service 75.0% 28.6% 98.3% 88.5% 84.9%
Filled by Telemedicine 7.0 4.0 0 0 4.0
Percentage Filled by Telemedicine 0.0% 57.1% 0.0% 0.0% 4.1%
Filled by Registry 0 1.0 0 9.0 10.0
Percentage Filled by Registry 0.0% 14.3% 0.0% 11.9% 10.2%
Total Filled Positions 3.0 7.0 11.5 76.0 97.5
Total Percentage Filled 75.0% 100.0% 98.3% 100.4% 99.1%
Appointments in Last 12 Months 1.0 1.0 1.5 27.0 30.5
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 0 7.0 7.0
Adjusted Total: Filled Positions 3.0 7.0 11.5 69.0 90.5
Adjusted Total: Percentage Filled 75.0% 100.0% 98.3% 91.1% 92.0%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes the classifications of Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Notes: The OIG does not independently validate staffing data received from the department. Positions are based on
fractional time-base equivalents.
Source: Cycle 7 medical inspection preinspection questionnaire received on 12-27-24, from California Correctional
Health Care Services.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 9
Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted above, the OIG
presents selected measures from the Healthcare Effectiveness Data and Information Set
(HEDIS) for comparison purposes. The HEDIS is a set of standardized quantitative
performance measures designed by the National Committee for Quality Assurance to
ensure that the public has the data it needs to compare the performance of health care
plans. Because the Veterans Administration no longer publishes its individual HEDIS
scores, we removed them from our comparison for Cycle 7. Likewise, Kaiser (commercial
plan) no longer publishes HEDIS scores. However, through the California Department of
Health Care Services’ Medi-Cal Managed Care Technical Report, the OIG obtained
California Medi-Cal and Kaiser Medi-Cal HEDIS scores to use in conducting our
analysis, and we present them here for comparison.
HEDIS Results
We considered ISP’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. Currently, only two HEDIS
measures are available for comparison: poor HbA1c control, which measures the
percentage of diabetic patients who have poor blood sugar control, and the colorectal
cancer screening rate for patients ages 45 to 75. We list the applicable HEDIS measures
in Table 4.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—ISP’s
percentage of patients with poor HbA1c control was significantly lower at six percent,
indicating very good performance on this measure.
Immunizations
Statewide comparative data were not available for immunization measures; however, we
include these data for informational purposes. ISP had a 35 percent influenza
immunization rate for adults 18 to 64 years old and a 66 percent influenza immunization
rate for adults 65 years of age and older.9 The pneumococcal vaccination rate was
81 percent.10
Cancer Screening
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—ISP’s
colorectal cancer screening rate of 69 percent was higher than California Medi-Cal, but
9 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable result.
10 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines (PCV13,
PCV15, and PCV20), or 23 valent pneumococcal vaccine (PPSV23), depending on the patient’s medical
conditions. For the adult population, the influenza or pneumococcal vaccine may have been administered at a
different institution other than where the patient was currently housed during the inspection period.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 10
lower than Kaiser Northern California (Medi-Cal) and Kaiser Southern California (Medi-
Cal) indicating a need for improvement on this measure.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 11
Table 4. ISP Results Compared With State HEDIS Scores
ISP California California
Kaiser Kaiser
Cycle 7 California NorCal SoCal
HEDIS Measure Results * Medi-Cal † Medi-Cal † Medi-Cal †
HbA1c Screening 100% – – –
Poor HbA1c Control (> 9.0%) ‡,§ 6% 33% 26% 19%
HbA1c Control (< 8.0%) ‡ 86% – – –
Blood Pressure Control (< 140/90) ‡ 98% – – –
Eye Examinations 90% – – –
Influenza – Adults (18 – 64) 35% – – –
Influenza – Adults (65 +) 66% – – –
Pneumococcal – Adults (65 +) 81% – – –
Colorectal Cancer Screening 69% 40% 71% 71%
Notes and Sources
* Unless otherwise stated, data were collected in December 2024 by reviewing medical records from a
sample of ISP’s population of applicable patients. These random statistical sample sizes were based on a
95 percent confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication
Medi-Cal Managed Care External Quality Review Technical Report, dated July 1, 2023 – June 30, 2024
(published April 2025); https://www.dhcs.ca.gov/dataandstats/reports/Documents/CA2023-24-Medi-Cal-
Managed-Care-Physical-Health-External-Quality-Review-Technical-Report-Vol1-F1.pdf.
‡ For this indicator, the entire applicable ISP population was tested.
§ For this measure only, a lower score is better.
Source: Institution information provided by the California Department of Corrections and Rehabilitation.
Health care plan data were obtained from the CCHCS Master Registry.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 12
Recommendations
As a result of our assessment of ISP’s performance, we offer the following
recommendations to the department:
Diagnostic Services
• The department should develop and implement strategies, such as an
electronic solution, to ensure providers create patient notification letters at
the time of endorsement, and the patient notification letter automatically
populates accurately with all required elements per CCHCS policy.
Emergency Services
• Nursing leadership should analyze the challenges to nurses performing
thorough assessments and reassessments of emergent and urgent conditions.
Leadership should implement remedial measures as appropriate.
• Health care leadership should analyze the root cause(s) of the Emergency
Medical Response Review Committee (EMRRC) not thoroughly reviewing
emergency response events or accurately detailing findings and should
implement remedial measures as appropriate.
Health Care Environment
• Health care leadership should determine the root cause(s) for staff not
following all required universal hand hygiene precautions and should
implement remedial measures as appropriate.
• Health care leadership should determine the root cause(s) for staff not
following equipment and medical supply management protocols and should
implement remedial measures as appropriate.
• Nursing leadership should determine the root cause(s) for staff not ensuring
the emergency medical response bags (EMRBs) are regularly inventoried and
sealed and should implement remedial measures as appropriate.
Transfers
• Health care leadership should identify the challenges to medication
continuity for patients returning from hospitalizations or emergency rooms.
Medication Management
• Medical and nursing leadership should analyze the root cause(s) of the challenges to staff
ensuring chronic care medications, newly prescribed medications, hospital discharge
medications, and specialized medical housing patients are administered timely and
without interruption. Leadership should implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 13
Nursing Performance
• Nursing leadership should analyze the challenges to nurses performing
thorough assessments, consulting with the provider regarding abnormal test
findings in a timely manner, and assessing and documenting wound care
thoroughly. Leadership should implement remedial measures as appropriate.
Specialized Medical Housing
• Nursing leadership should develop strategies to ensure specialized medical
housing nursing staff perform thorough patient assessments and
documentation and should implement remedial measures as appropriate.
Specialty Services
• Medical leadership should determine the root cause(s) of challenges to the
timely provision of high- and medium-priority specialty appointments and
should implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 14
Indicators
Access to Care
Overall
In this indicator, OIG inspectors evaluated the institution’s performance in providing
Rating
patients with timely clinical appointments. Our inspectors reviewed scheduling and
Adequate
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
Case Review
specialists. Furthermore, we evaluated the follow-up appointments for patients who
Rating
received specialty care or returned from an off-site hospitalization.
Adequate
Compliance
Ratings and Results Overview
Score
Adequate
Case Review Rating Compliance Rating and Score (81.5%)
Proficient Proficient (91.6%)
Case review found ISP performed outstandingly in this indicator. We found all nursing
appointments occurred timely, and all provider appointments, including outpatient, after
hospitalization, specialty, or TTA events, occurred timely. After reviewing all aspects of
access to care, the OIG rated the case review component of this indicator proficient.
Compliance testing similarly showed ISP performed excellently in this indicator. Nurses
always reviewed patient sick call requests and almost always completed face-to-face
triage within required time frames. Staff often timely evaluated patients returning from
hospitalizations and specialty appointments as well as patients newly transferred into
ISP. However, staff needed improvement in timely completing chronic care appointments
for patients. Based on the overall Access to Care compliance score result, the OIG rated
the compliance testing component of this indicator proficient.
Case Review and Compliance Testing Results
OIG clinicians reviewed 385 provider, nursing, urgent or emergent care (TTA), specialty,
and hospital events requiring the institution to generate appointments. We found no
deficiencies related to access to care.
Access to Clinic Providers
Compliance testing showed staff timely completed all nurse-to-provider appointments
(MIT 1.005, 100%). However, they only timely completed just more than half of chronic
care follow-up appointments (MIT 1.001, 60.0%). In contrast, OIG clinicians reviewed 133
clinic provider appointments and did not identify any deficiencies.
Access to Specialized Medical Housing Providers
ISP performed excellently with access to specialized medical housing providers. The OIG
clinicians reviewed 22 provider encounters and did not identify any deficiencies related to
timely completing provider appointments.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 15
Access to Clinic Nurses
Compliance testing showed nurses reviewed all nurse sick call requests on the same day
they were received (MIT 1.003, 100%). The nurses also completed almost all face-to-face
encounters within the required one business day (MIT 1.004, 96.7%). Similarly, OIG
clinicians reviewed 89 nursing encounters and did not identify any deficiencies related to
clinic nurse access.
Access to Specialty Services
Compliance testing revealed a variable performance in completing initial high-priority
(MIT 14.001, 66.7%), medium-priority (MIT 14.004, 73.3%), and routine-priority (MIT
14.007, 100%) specialty appointments within required time frames. Compliance testing
also showed most follow-up specialty appointments occurred timely, regardless of order
priority (MIT 14.003, 75.0%, MIT 14.006, 81.8%, and MIT 14.009. 87.5%). In contrast, OIG
clinicians reviewed 94 specialty events and did not identify any access deficiencies.
Follow-Up After Specialty Services
Compliance testing showed nearly all provider appointments after specialty services
occurred within required time frames (MIT 1.008, 93.0%). OIG clinicians did not identify
any missed or delayed provider appointments.
Follow-Up After Hospitalization
Compliance testing showed nearly all provider appointments after hospitalizations
occurred within required time frames (MIT 1.007, 91.3%). OIG clinicians reviewed 20
hospital returns and did not identify any access deficiencies.
Follow-Up After Urgent or Emergent Care (TTA)
Providers always evaluated their patients following a TTA event as medically indicated.
OIG clinicians reviewed 27 TTA events and did not identify any access deficiencies.
Follow-Up After Transferring Into ISP
Compliance testing showed most provider appointments for newly arrived patients
occurred timely (MIT 1.002, 83.3%). OIG clinicians reviewed three transfer-in events and
did not identify any missed or delayed provider appointments.
Clinician On-Site Inspection
ISP has five main clinics: A, B, C, D, and E. Each clinic was staffed with one provider and
an office technician who attended the morning huddle. The office technicians reported
scheduling and bundling provider appointments to optimize each appointment. Each
provider evaluated about 12 patients per day. At the time of the on-site inspection, ISP
staff reported five overdue nurse appointments but no provider appointment backlog.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 16
Compliance Testing Results
Patients had access to health care services request forms in all of six housing units
randomly inspected (MIT 1.101, 100%).
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 17
Compliance Score Results
Table 5. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent chronic
care visit within the health care guideline’s maximum allowable interval or 15 10 0 60.0%
within the ordered time frame, whichever is shorter? (1.001)
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 20 4 1 83.3%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
30 0 0 100%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
29 1 0 96.7%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
8 0 22 100%
maximum allowable time or the ordered time frame, whichever is the
shorter? (1.005)
Sick call follow-up appointments: If the primary care provider ordered a
follow-up sick call appointment, did it take place within the time frame 2 0 28 100%
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
21 2 0 91.3%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
40 3 2 93.0%
occur within required time frames? (1.008) *
Clinical appointments: Do patients have a standardized process to obtain
6 0 0 100%
and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 91.6%
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 18
Table 6. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the N/A N/A N/A N/A
required time frame? (12.003)
For patients received from a county jail: Did the patient receive a history
and physical by a primary care provider within seven calendar days (prior N/A N/A N/A N/A
to 07/2022) or five working days (effective 07/2022)? (12.004)
Was a written history and physical examination completed within the
9 1 0 90.0%
required time frame? (13.002)
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 10 5 0 66.7%
Request for Service? (14.001)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 9 3 3 75.0%
provider? (14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or the Physician Request 11 4 0 73.3%
for Service? (14.004)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 9 2 4 81.8%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 15 0 0 100.0%
for Service? (14.007)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care 7 1 7 87.5%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 19
Recommendations
The OIG offers no recommendations for this indicator.
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Cycle 7, Ironwood State Prison | 20
Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s performance in timely
completing radiology, laboratory, and pathology tests. Our inspectors determined
whether the institution properly retrieved the resultant reports and whether providers
reviewed the results correctly. In addition, in Cycle 7, we examined the institution’s
performance in timely completing and reviewing immediate (STAT) laboratory tests.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (76.7%)
Overall, case review found ISP performed well in diagnostic services. Staff completed all
radiology tests and laboratory tests within requested time frames. The providers
sometimes did not communicate test results to their patients with complete results
notification letters; however, these deficiencies were minor. Taking all factors into
consideration, the OIG rated the case review component of this indicator adequate.
In Cycle 7, ISP’s overall compliance testing score improved for this indicator. Staff
performance ranged from good to excellent in timely completing radiology and
laboratory services. Provider performance also ranged from very good to excellent in
reviewing and endorsing diagnostic test results. However, staff needed improvement in
retrieving pathology reports and generating complete patient test result notification
letters with all required elements. Based on the overall Diagnostics Services compliance
score result, the OIG rated the compliance component of this indicator adequate.
Case Review and Compliance Testing Results
The OIG clinicians reviewed 103 diagnostic events and identified 19 deficiencies, three of
which were significant. Of the 19 deficiencies, 18 related to health information
management and one related to test completion.11
Test Completion
Compliance testing showed staff completed all radiology tests within requested time
frames (MIT 2.001, 100%). OIG clinicians reviewed 17 radiology tests and did not identify
any missed or delayed test completions.
Compliance testing showed staff completed most laboratory tests timely (MIT 2.004,
80.0%). Similarly, OIG clinicians reviewed 79 laboratory tests and did not identify any
deficiencies related to test completion. OIG clinicians reviewed five electrocardiograms
and found one test was not completed as requested:
11 Diagnostic deficiencies occurred in cases 2, 5–7, 15, 16, 41, and 44–47. Significant deficiencies
occurred in cases 2 and 15.
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Cycle 7, Ironwood State Prison | 21
• In case 15, a provider requested an electrocardiogram to be completed within
10 days; however, the test was not done.
Compliance testing and OIG clinicians did not have any STAT laboratory tests to review
in their samples (MIT 2.007, N/A).
Health Information Management
ISP performed variably in retrieving diagnostic reports. Compliance testing revealed ISP
staff sometimes retrieved pathology reports within the required time frames (MIT 2.010,
70.0%). OIG clinicians reviewed two pathology events and found staff retrieved the
reports timely. OIG clinicians found staff retrieved all radiology reports timely and
retrieved most laboratory reports timely. However, we found staff did not retrieve two
results as follows:
• In case 2, the patient returned from a hospitalization with the diagnosis of
pneumonia. The results for blood cultures and sputum cultures were pending
upon hospital discharge; however, ISP staff did not retrieve these laboratory
test results.
• Also in case 2, the patient returned from another hospitalization with the
diagnoses of pneumonia and sepsis. The results for blood cultures and fecal
occult blood tests were pending upon hospital discharge; however, ISP staff
did not retrieve these laboratory test results.
Compliance testing showed providers endorsed nearly all radiology and pathology
reports, as well as all laboratory test results timely (MIT 2.002, 90.0%, MIT 2.011, 90.0%,
and MIT 2.005, 100%). OIG clinicians similarly found providers endorsed all diagnostic
reports timely.
Compliance testing revealed providers performed poorly in timely generating patient test
result notification letters for radiology results, laboratory results, and pathology results
(MIT 2.003, 60.0%, MIT 2.006, 60.0%, and MIT 2.012, 40.0%). OIG clinicians also identified
14 examples of patient letters missing at least one of the required elements. The following
is an example:
• In case 5, a provider sent a patient test result notification letter but did not
include whether the test result was within normal limits.
We also found the provider did not send notification letters informing patients of
pathology results on two occasions. The following is an example:
• In case 7, a provider reviewed a colon polyp pathology report but did not
send a patient test result notification letter.
Clinician On-Site Inspection
OIG clinicians met with diagnostic supervisors and staff. ISP reported having three full-
time phlebotomists, who collected about 30 laboratory tests per day, and one full-time
radiology technician, who performed general x-rays on-site. Supervisors reported having
openings for a senior radiology technician and a part-time radiology technician; however,
a senior radiology technician from a nearby institution provided assistance when
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Cycle 7, Ironwood State Prison | 22
necessary. ISP also performed on-site monthly mobile mammogram, ultrasound, CT, and
MRI services.12
OIG clinicians discussed the missed laboratory results during patients’ hospitalizations.
The medical record supervisor explained ISP staff had a difficult time retrieving
laboratory results from one particular community hospital, as ISP staff did not have
direct access to the hospital’s electronic medical record system.
12 A CT is a computed, or computerized, tomography scan while an MRI is a magnetic resonance imaging scan.
Both create detailed images of the organs and tissues to detect diseases and abnormalities.
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Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
6 4 0 60.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
8 2 0 80.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
10 0 0 100%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
6 4 0 60.0%
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
N/A N/A N/A N/A
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frames? (2.008)
Laboratory: Did the health care provider endorse the STAT laboratory
N/A N/A N/A N/A
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within the
7 3 0 70.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
9 1 0 90.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
4 6 0 40.0%
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 76.7%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Ironwood State Prison | 24
Recommendations
• The department should develop and implement strategies, such as an
electronic solution, to ensure providers create patient notification letters at
the time of endorsement, and the patient notification letter automatically
populates accurately with all required elements per CCHCS policy.
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Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed emergency medical services by examining the timeliness and
appropriateness of clinical decisions made during medical emergencies. Our evaluation
included examining the emergency medical response, cardiopulmonary resuscitation
(CPR) quality, triage and treatment area (TTA) care, provider performance, and nursing
performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services.
The OIG assessed the institution’s emergency services solely through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
In this cycle, case review found ISP performed satisfactorily in providing emergency care.
Compared with Cycle 6, we reviewed almost twice the number of urgent and emergent
events, and ISP continued to perform well. Health care first responders (HCFR)
frequently performed good assessments, intervened as required, and documented well.
TTA nurses performed efficiently during emergencies and completed thorough
documentation; however, we identified a pattern of deficiencies with incomplete nursing
assessments. Providers often made good decisions and timely documented urgent and
emergent events. Nursing and medical leadership completed timely clinical reviews but
did not always identify the same deficiencies OIG clinicians identified. Considering all
factors, the OIG rated this indicator adequate.
Case Review Results
We reviewed 27 urgent or emergent events and found 10 emergency care deficiencies. Of
these 10 deficiencies, three were significant.13
Emergency Medical Response
ISP staff responded promptly to emergencies throughout the institution. They activated
emergency medical services (EMS) and notified TTA staff in a timely manner. The HCFRs
frequently performed good assessments, intervened as required, and documented well.
Cardiopulmonary Resuscitation Quality
During this period, we reviewed only one case in which CPR was initiated.14 Custody and
medical staff worked cohesively, provided prompt care, transported the patient to the
13 Deficiencies occurred in cases 2, 3, 12, 13, and 41. Significant deficiencies occurred in cases 3, 12, and 41.
14 Staff performed CPR on the patient in case 3.
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TTA for additional interventions, and immediately activated the 9-1-1 system from the
scene. In this one CPR case, we identified the following deficiencies:
• In case 3, the LVN responded to a medical emergency for the unresponsive
patient with multiple penetrating wounds and bleeding and noted a weak
pulse. Shortly after, the RN arrived at the patient's side but did not assess the
patient's respiratory rate or pulse. During transport to the TTA, the patient
stopped breathing, and nurses initiated CPR. Nursing staff initially delayed
administering oxygen then improperly placed the patient on a nonrebreather
mask instead of providing positive pressure ventilation.15 Furthermore,
nursing staff inconsistently documented the method of administering
oxygen.
Provider Performance
Providers were generally available when TTA nurses requested consultation. Providers
also made appropriate triage decisions and timely documented emergent events. The OIG
did not identify any deficiencies related to provider performance.
Nursing Performance
ISP nursing staff usually performed well during emergent events and generally provided
appropriate nursing assessments and interventions. However, we identified a pattern of
deficiencies with incomplete nursing assessments. The following cases are examples:
• In case 2, the TTA RN responded to a medical emergency call for a patient
with an allergic reaction and rash. The nurse documented the patient was
experiencing an allergic reaction after taking antibiotics. However, the TTA
RN did not inquire about the onset time of the rash, when the last dose of
antibiotic was taken, and whether the patient had a history of allergic
reactions. Moreover, the nurse did not document the general appearance and
size of the rash.
• In case 41, the outpatient housing unit (OHU) and TTA nursing staff
responded to a medical emergency for a patient with altered level of
consciousness. The HCFR documented the patient was unresponsive but did
not document obtaining vital signs such as blood pressure, respiratory rate or
oxygen saturation. The patient became alert shortly after and was transferred
to the TTA. The TTA RN documented the patient had stroke-like symptoms
but did not document what neurological signs or symptoms the patient
presented with. In addition, the TTA RN did not obtain vital signs until over
one hour after the patient arrived to the TTA.
15 A nonrebreather mask is a device used to assist in the delivery of oxygen but requires the patient be able to
breathe unassisted. Positive pressure ventilation during CPR is delivered via an Ambu-bag and is recommended
for those patients who are unresponsive with no breathing or abnormal breathing. It ensures oxygen is delivered
to vital organs until spontaneous breathing and heartbeat can be restored.
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Nursing Documentation
Nurses in the TTA usually performed thorough documentation for emergent events. We
identified no pattern of deficiencies and noted nursing staff always documented
medication administration times on the medication administration record (MAR).
Emergency Medical Response Review Committee
The EMRRC met twice per month and discussed emergency responses and unscheduled
transports to the community hospital. However, compliance testing revealed deficient
incident packages due to the EMRRC event checklists being incomplete in almost half
the events reviewed (MIT 15.003, 58.3%). In contrast, OIG clinicians found nursing and
medical leadership performed most clinical reviews; however, in three emergency
responses or unscheduled transports to the community hospital, the nursing and medical
leadership and the EMRRC did not identify the same opportunities for improvement OIG
clinicians identified.16 The following are examples:
• In case 2, a clinical review was completed for the patient who was transferred to
higher level of care with shortness of breath. However, during the review process,
the following deficiencies was not identified: the TTA RN did not assess the
onset time of SOB and did not re-assess shortness of breath. Additionally, the
patient was prescribed inhalers however, the TTA RN did not assess rescue
inhaler use.
• In case 3, nursing staff responded an unconscious patient. The patient was
treated for multiple penetrating wounds and bleeding in the TTA. The patient
did not respond to resuscitative measures and was pronounced deceased by EMS.
During the review process, a delay in oxygen administration and improper
oxygen application by nursing staff was not identified.
Clinician On-Site Inspection
OIG clinicians went to the TTA and spoke to staff during our on-site inspection, The
institution had three medical bays. Two bays were used for urgent or emergent care, and
one was used for observation. One designated provider was available during regular
business hours; otherwise, providers were assigned on an on-call basis and were available
by telephone or via telemedicine. The nurses reported the TTA was staffed with two RNs
during each shift and often three RNs on the weekends to assist with the weekend sick
call process or assist with patient care in the OHU.
The TTA RNs reported they were notified of emergencies via a phone call or by the
officers who were located in close proximity to the TTA. The TTA RNs reported they had
no access to radios in the TTA but reported having good communication with custody
staff.
During the on-site inspection, the OIG clinicians observed the daily central health
huddle. The TTA RNs conducted the central health huddle via Microsoft teams. The TTA
nurses discussed all TTA encounters from the previous day as well as patients returning
from the community hospital and offsite specialty service appointments, including
16 ISP’s nursing and medical leadership did not identify opportunities for improvement in cases 2, 3, and 41.
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Cycle 7, Ironwood State Prison | 28
specialty services recommendations. The huddle was very well run with good
participation and communication evident.
The TTA RNs we interviewed were pleasant and knowledgeable. The TTA RNs had many
years of experience within the institution, and they reported they felt supported by their
leadership.
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Recommendations
• Nursing leadership should analyze the challenges to nurses performing
thorough assessments and reassessments of emergent and urgent conditions.
Leadership should implement remedial measures as appropriate.
• Health care leadership should analyze the root cause(s) of the Emergency
Medical Response Review Committee (EMRRC) not thoroughly reviewing
emergency response events or accurately detailing findings and should
implement remedial measures as appropriate.
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Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link
in high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (88.9%)
OIG clinicians found ISP performed well in this indicator. Staff retrieved all specialty
reports, all radiology reports, all pathology reports, most hospital records, and most
laboratory results within the required time frames. We identified two late specialty report
endorsements and 16 incomplete or missing patient test result notification letters. Taking
all factors into consideration, the OIG rated the case review component of this indicator
adequate.
Compliance testing showed staff performed very well in health information management.
Staff always timely scanned patient sick call requests. They frequently scanned specialty
reports as well as scanned and reviewed hospital discharge reports within required time
frames. Staff also satisfactorily labeled and scanned medical records into the correct
patient files. Based on the overall Health Information Management compliance score
result, the OIG rated the compliance testing component of this indicator proficient.
Case Review and Compliance Testing Results
OIG clinicians reviewed 747 events and identified 23 deficiencies related to health
information management. Of these deficiencies, two were significant.17
Hospital Discharge Reports
ISP staff performed well in hospital records management. Compliance testing showed
staff retrieved most hospital records timely (MIT 4.003, 81.0%). ISP staff often retrieved
the hospital discharge reports with key elements and providers endorsed most hospital
records timely (MIT 4.005, 87.0%). OIG clinicians reviewed 20 off-site emergency
department and hospital encounters and found staff retrieved only one hospital record
late:
17 Deficiencies occurred in cases 2, 4, 5–7, 15, 16, 41, and 44–47. Significant deficiencies occurred in case 2.
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• In case 16, the patient was discharged from a community hospital with a
diagnosis of cellulitis requiring antibiotic treatment; however, the ISP staff
retrieved the hospital record three days late.18
Specialty Reports
Compliance testing showed ISP staff retrieved and scanned almost all specialty reports
within required time frames (MIT 4.002, 93.3%). ISP staff received, and providers
endorsed, all high-priority (MIT 14.002, 100%), most medium-priority (MIT 14.005, 86.7%),
and most routine-priority (MIT 14.008, 80.0%) specialty reports timely. OIG clinicians
reviewed 94 specialty appointments and found staff retrieved all specialty reports timely.
For specialty reports, OIG clinicians identified only two deficiencies related to late
endorsements.19
Diagnostic Reports
Compliance testing revealed ISP staff intermittently retrieved pathology reports on time
(MIT 2.010, 70.0%). OIG clinicians reviewed two pathology events and found staff
retrieved reports timely. OIG clinicians also found ISP staff retrieved all radiology reports
and most laboratory results timely. Staff did not retrieve two laboratory results, and we
discussed these deficiencies in the Diagnostic Services indicator.20
Compliance testing showed providers endorsed all laboratory (MIT 2.005, 100%) and most
radiology (MIT 2.002, 90.0%) reports within required time frames. The providers also
endorsed almost all pathology reports within required time frames (MIT 2.011, 90.0%).
Similarly, OIG clinicians found providers endorsed all diagnostic and pathology reports
timely.
OIG clinicians identified 16 deficiencies related to missed or incomplete letters for
radiology, laboratory, and pathology results. Please refer to the Diagnostic Services
indicator for additional information.
Urgent and Emergent Records
OIG clinicians reviewed 27 emergency care events and identified no deficiencies related
to documentation. Both the providers and nurses recorded these events very well.
Scanning Performance
Compliance testing showed all patient health care request forms were scanned timely
(MIT 4.001, 100%), and most medical documents were scanned, labeled, and filed
appropriately (MIT 4.004, 83.3%). OIG clinicians identified only one document not
scanned into the medical record as follows:
• In case 15, a provider documented the patient signed a refusal for a provider
appointment; however, staff did not scan the refusal into the patient’s medical record.
18 Cellulitis is a skin and soft tissue infection caused by bacteria.
19 Deficiencies occurred in cases 4 and 7.
20 Deficiencies occurred in case 2.
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Cycle 7, Ironwood State Prison | 32
Legibility
OIG clinicians found most hand-written nursing assessments of the sick call requests
were legible, except one case in which we could not read the nurse’s signature.21
Clinician On-Site Inspection
OIG clinicians discussed health information management processes with the ISP health
information management supervisor. The supervisor described a tracking process for
specialty consultations, hospital records, and pathology results to ensure these
documents are retrieved timely. ISP health information management staff also have
access to the electronic medical record systems for five contracted hospitals to facilitate
retrieving medical records.
21 A deficiency occurred in case 2.
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Compliance Score Results
Table 8. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s electronic
20 0 10 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
28 2 15 93.3%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 17 4 2 81.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
20 4 0 83.3%
and included in the correct patients’ files? (4.004)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 20 3 0 87.0%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 88.9%
Source: The Office of the Inspector General medical inspection results.
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Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the
10 0 0 100%
laboratory report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did
N/A N/A N/A N/A
nursing staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
7 3 0 70.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
9 1 0 90.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
4 6 0 40.0%
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 14 0 1 100%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required 13 2 0 86.7%
time frame? (14.005)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 12 3 0 80.0%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 36
Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection
control, sanitation procedures, medical supplies, equipment management, and
examination rooms. Inspectors also tested clinics’ performance in maintaining auditory
and visual privacy for clinical encounters. Compliance inspectors asked the institution’s
health care administrators to comment on their facility’s infrastructure and its ability to
support health care operations. The OIG rated this indicator solely on the compliance
score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (68.1%)
Overall, ISP’s performance in health care environment needed improvement. Medical
supply storage areas in the clinics contained unidentified or unorganized labeled medical
supplies. Several applicable clinics tested did not meet the requirements for essential core
medical equipment and supplies. In addition, staff did not regularly sanitize or wash their
hands during patient encounters. Lastly, emergency medical response bags (EMRBs) were
missing staff verification, had not been properly inventoried when seal tags changed, or
contained compromised sterile medical supply packaging. Based on the overall Health
Care Environment compliance score result, the OIG rated this indicator inadequate.
Compliance Testing Results
Waiting Areas
We inspected only indoor waiting
areas as ISP had no outdoor
waiting areas. Health care and
custody staff reported the existing
waiting areas contained sufficient
seating capacity (see Photo 1,
right, and Photo 2, next page).
During our inspection, we did not
observe overcrowding in any of
the clinics’ indoor waiting areas.
Photo 1. Patient waiting area (photographed on 1-13-25).
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Cycle 7, Ironwood State Prison | 37
Photo 2. Patient waiting area (photographed on 1-13-25).
Clinic Environment
All clinic environments were sufficiently conducive for medical care; they provided
reasonable auditory privacy, appropriate waiting areas, wheelchair accessibility, and
nonexamination room workspace (MIT 5.109, 100%).
All clinics we observed contained appropriate space, configuration, supplies, and
equipment to allow their clinicians to perform proper clinical examinations (MIT 5.110,
100%).
Clinic Supplies
Only five of the 10 clinics followed proper medical
supply storage and management protocols (MIT
5.107, 50.0%). We found one or more of the
following deficiencies in five clinics: compromised
sterile medical supply packaging (see Photo 3);
expired medical supplies (see Photos 4 and 5, next
page); unidentified or unorganized labeled medical
supplies; cleaning materials stored with medical
supplies; and medical supplies directly stored on
the floor.
Four of the 10 clinics met requirements for
essential core medical equipment and supplies
(MIT 5.108, 40.0%). We found one or more of the
following deficiencies in six clinics: missing
nebulization unit or examination table disposable
paper; staff did not properly document defibrillator
performance test within the last 30 days; and
several clinic daily glucometer quality control logs Photo 3. Compromised sterile medical supply
were inaccurate. packaging (photographed on 1-13-25).
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Photo 4. Expired medical supply dated
October 31, 2024 (photographed
on 1-13-25).
Photo 5. Expired medical supply dated May 30, 2024
(photographed on 1-15-25).
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We examined EMRBs to determine whether they contained all essential items. We
checked whether staff inspected the bags daily and inventoried them monthly. Only one
of the eight applicable EMRBs passed our test (MIT 5.111, 12.5%). We found one or more
of the following deficiencies with seven EMRBs: staff did not ensure the EMRBs’
compartments were sealed and intact; staff had not inventoried the EMRBs when seal
tags were replaced; EMRBs contained compromised sterile medical supply packaging;
and staff inaccurately logged the EMRBs’ glucometer control solution range when
performing the daily glucometer quality control.
Medical Supply Management
ISP staff always appropriately stored clinic medical supplies in the medical supply
storage areas outside the clinics (e.g., warehouse, Conex containers, etc.) (MIT 5.106,
100%).
According to the Chief Executive Officer (CEO), health care leadership did not have any
issues with the medical supply process. Health care and warehouse managers expressed
no concerns about the medical supply chain or their communication process with the
existing system in place.
Infection Control and Sanitation
Staff appropriately cleaned, sanitized, and disinfected seven of nine applicable clinics
(MIT 5.101, 77.8%). In two clinics, we found one or both of the following deficiencies: the
clinic’s cabinet drawer or cabinet under the sink were unsanitary.
Staff in seven of 10 clinics (MIT 5.102, 70.0%) properly sterilized or disinfected medical
equipment. In two clinics, staff did not mention disinfecting the examination table as
part of their daily start-up protocol. In one clinic, we observed the clinician utilize the
examination table without a disposable paper during a patient encounter.
We found operational sinks and hand hygiene supplies in the examination rooms in seven
of 10 clinics (MIT 5.103, 70.0%). In three clinics, the patient restrooms lacked antiseptic
soap or disposable hand towels.
We observed patient encounters in seven applicable clinics. In five of those seven clinics,
clinicians did not wash their hands before or after examining their patients, or during
subsequent regloving (MIT 5.104, 28.6%).
Health care staff in all clinics followed proper protocols to mitigate exposure to
bloodborne pathogens and contaminated waste (MIT 5.105, 100%).
Physical Infrastructure
At the time of our medical inspection, the institution’s administrative team reported no
ongoing health care facility improvement program construction projects. The
institution’s health care management and plant operations manager reported all clinical
area infrastructures were in good working order (MIT 5.999).
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Cycle 7, Ironwood State Prison | 40
Compliance Score Results
Table 10. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately disinfected,
7 2 1 77.8%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 7 3 0 70.0%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
7 3 0 70.0%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
2 5 3 28.6%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
10 0 0 100%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 1 0 0 100%
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
5 5 0 50.0%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
4 6 0 40.0%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
10 0 0 100%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
10 0 0 100%
providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency crash
carts inspected and inventoried within required time frames, and do they 1 7 2 12.5%
contain essential items? (5.111)
Does the institution’s health care management believe that all clinical areas
This is a nonscored test. Please see the
have physical plant infrastructures that are sufficient to provide adequate
indicator for discussion of this test.
health care services? (5.999)
Overall percentage (MIT 5): 68.1%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Ironwood State Prison | 41
Recommendations
• Health care leadership should determine the root cause(s) for staff not
following all required universal hand hygiene precautions and should
implement remedial measures as appropriate.
• Health care leadership should determine the root cause(s) for staff not
following equipment and medical supply management protocols and should
implement remedial measures as appropriate.
• Nursing leadership should determine the root cause(s) for staff not ensuring
the emergency medical response bags (EMRBs) are regularly inventoried and
sealed and should implement remedial measures as appropriate.
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Cycle 7, Ironwood State Prison | 42
Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions.
For newly arrived patients, our inspectors assessed the quality of health care screenings
and the continuity of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, inspectors checked
whether staff reviewed patient medical records and determined the patient’s need for
medical holds. They also assessed whether staff transferred patients with their medical
equipment and gave correct medications before patients left. In addition, our inspectors
evaluated staff performance in communicating vital health transfer information, such as
preexisting health conditions, pending appointments, tests, and specialty referrals.
Inspectors further confirmed whether staff sent complete medication transfer packages
to receiving institutions. For patients who returned from off-site hospitals or emergency
rooms, inspectors reviewed whether staff appropriately implemented recommended
treatment plans, administered necessary medications, and scheduled appropriate follow-
up appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (85.8%)
OIG clinicians found ISP performed sufficiently in the transfer process. Nurses screened
patients appropriately and patients received good assessments and care when they
returned from the hospital or emergency rooms. In addition, patients received timely
follow-up appointments. However, we found opportunities for improvement in
documentation and medication continuity. Considering all factors, the OIG rated the
case review component of this indicator adequate.
Compliance testing showed ISP performed well in this indicator. The institution
performed excellently in completing the assessment and disposition sections of the
screening process and ensured transfer packets for departing patients included all
required documents and medications. In contrast, the institution scored low in
completing initial health screening forms. The institution also needed improvement in
medication continuity for newly transferred patients. Based on the overall Transfers
compliance score result, the OIG rated the compliance testing component of this
indicator proficient.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 43
Case Review and Compliance Testing Results
OIG clinicians reviewed 32 events in 17 cases in which patients transferred into or out of
the institution or returned from an off-site hospital or emergency room. We identified 13
deficiencies, four of which were significant.22
Transfers In
ISP’s transfer-in process had a mixed performance. Compliance testing showed nurses
needed improvement with completing the initial health screening thoroughly and within
required time frames (MIT 6.001, 68.0%). Nursing staff did not always follow up with
additional questions when patients responded “Yes” to some of the screening questions,
and we found instances in which nursing staff completed the initial health screening
after the patient moved to the housing unit. However, when required, nurses always
completed the assessment and disposition section on the initial health screening form on
the same day as the health screening (MIT 6.002, 100%). OIG clinicians reviewed six
events and identified two minor deficiencies.23 Our clinicians found nurses performed
very well in completing assessments.
Compliance testing showed ISP performed satisfactorily with ensuring providers
evaluated newly arrived patients within required time frames (MIT 1.002, 83.3%). OIG
clinicians found all patients were seen timely.
Case review and compliance testing showed mixed results in medication continuity for
transfer-in patients. Compliance data showed staff occasionally did not deliver prescribed
medications by the administration date and time ordered by providers (MIT 6.003, 75.0%).
In contrast, OIG clinicians did not identify any concerns with medication continuity.
Compliance testing revealed ISP performed well in scheduling preapproved specialty
appointments for patients who transferred into the institution (MIT 14.010, 85.0%). OIG
clinicians did not identify any concerns with specialty appointments.
Transfers Out
ISP’s transfer-out process was satisfactory. Compliance testing showed ISP performed
excellently with ensuring patients transferred out with their medications and required
documents (MIT 6.101, 100%). OIG clinicians reviewed six events and identified four
deficiencies, one of which was significant.24 We found nurses generally screened patients
appropriately, completed the interfacility transfer information, and ensured all patients
had their medical equipment. However, we identified one significant deficiency as
follows:
• In case 20, the nurse completed the preboarding transfer screening nine days
prior to the date of the patient’s departure. Subsequently on the day of
transfer, the nurse did not take vital signs, complete a Covid-19 screening,
document a pending transplant surgery referral, or ensure the patient had
22 Deficiencies occurred in cases 2, 11, 13, 16, 18, 19, and 20–22. Significant deficiencies occurred in cases 2, 11,
and 20.
23 Deficiencies occurred in cases 18 and 19.
24 Deficiencies occurred in cases 20–22. A significant deficiency occurred in case 20.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 44
their prescribed durable medical equipment (DME) and keep-on-person
medications.25
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at high risk for
lapses in care quality. These patients typically experienced severe illness or injury. They
require more care and place a strain on the institution’s resources. In addition, because
these patients have complex medical issues, successful health information transfer is
necessary for good quality care. Any transfer lapse can result in serious consequences for
these patients.
OIG clinicians reviewed 20 hospitalization events and identified four deficiencies, one of
which was significant.26 One deficiency was due to hospital records being scanned late
and is discussed in the Health Information Management indicator. The significant
deficiency related to hospital discharge medications and is addressed in the Medication
Management indicator. Overall, nurses performed good assessments, reviewed hospital
recommendations, and notified providers appropriately.
Compliance testing showed staff frequently scanned hospital discharge documents
within required time frames (MIT 4.003, 81.0%), and providers reviewed most documents
timely (MIT, 4.005, 87.0%). OIG clinicians found ISP staff scanned most documents within
required time frames, and providers reviewed most documents timely.
Compliance testing showed ISP performed poorly in medication continuity for patients
returning from hospitalizations (MIT 7.003, 27.8%). In contrast, OIG clinicians found
patients who returned from hospitals and emergency rooms generally received their
medications timely.
Compliance testing showed patients almost always received timely follow-up
appointments after returning from hospitals and emergency rooms (MIT 1.007, 91.3%).
OIG clinicians found all follow-up appointments for these patients occurred timely.
Clinician On-Site Inspection
At the receiving and release (R&R) area, OIG clinicians interviewed the on-duty RN, who
reported being the regular night shift nurse. The nurse was knowledgeable about the
transfer process. The R&R area had two screening rooms and was staffed with one nurse
on each shift. We were informed 15 to 20 patients transferred out of ISP weekly, and 25 to
30 patients transferred in weekly. The nurse reported generally obtaining from the TTA
any medications or supplies patients needed on departure or arrival during nonbusiness
hours. The R&R nurse also reported nursing morale was good, and rapport with nursing
leadership and custody staff was positive.
25 Durable medical equipment (DME) is medical equipment used for long periods of time and prescribed by a
provider for example wheelchairs, walkers, and CPAP machines. KOP means “keep-on-person” and refers to
medications a patient can keep and self-administer according to the directions provided.
26 Deficiencies occurred in cases 2, 11, 13 and 16. A significant deficiency occurred in case 11.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 45
Compliance On-Site Inspection and Discussion
R&R nursing staff ensured all nine applicable patients who transferred out of the
institution had the required medications, transfer documents, and assigned durable
medical equipment (MIT 6.101, 100%).
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Cycle 7, Ironwood State Prison | 46
Compliance Score Results
Table 11. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Did nursing
staff complete the initial health screening and answer all screening 17 8 0 68.0%
questions within the required time frame? (6.001)
For endorsed patients received from another CDCR institution: When
required, did the RN complete the assessment and disposition section of
the initial health screening form; refer the patient to the TTA if TB signs and 24 0 1 100%
symptoms were present; and sign and date the form on the same day staff
completed the health screening? (6.002)
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 3 1 21 75.0%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer packet 9 0 1 100%
required documents? (6.101)
Overall percentage (MIT 6): 85.8%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Ironwood State Prison | 47
Table 12. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 20 4 1 83.3%
patient seen by the clinician within the required time frame? (1.002)
Upon the patient’s discharge from the community hospital: Did the patient
receive a follow-up appointment with a primary care provider within the 21 2 0 91.3%
required time frame? (1.007)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 17 4 2 81.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 20 3 0 87.0%
review the report within five calendar days of discharge? (4.005)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient 5 13 5 27.8%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
23 2 0 92.0%
medications continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 4 1 0 80.0%
administered or delivered without interruption? (7.006)
For endorsed patients received from another CDCR institution: If the
patient was approved for a specialty services appointment at the sending
17 3 0 85.0%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Cycle 7, Ironwood State Prison | 49
Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in administering
prescription medications on time and without interruption. The inspectors examined this
process from the time a provider prescribed medication until the nurse administered the
medication to the patient. In addition to examining medication administration, our
compliance inspectors also tested many other processes, including medication handling,
storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (56.8%)
In this cycle, case review found ISP provided good medication management. The results
were similar to those in Cycle 6. ISP performed satisfactorily in ensuring medication
continuity for patients receiving new and chronic care medications, specialty and
hospital-recommended medications, and specialized medical housing medication as well
as medications for patients transferring into and out of the institution. Considering all
factors, the OIG rated the case review component of this indicator adequate.
Compliance testing showed ISP needed improvement in providing medication
management services. ISP performed sufficiently in ensuring medication continuity for
patients laying over at ISP. However, the institution performed poorly in providing
patients with chronic care medications, newly ordered medications, and community
hospital discharge medications. Based on the overall Medication Management
compliance score result, the OIG rated the compliance testing component of this
indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 110 events in 27 cases related to medications and found eight medication
deficiencies, two of which were significant.27
New Medication Prescriptions
Compliance testing revealed ISP needed improvement with timely administration and
availability of new prescription medications (MIT 7.002, 72.0%). In contrast, OIG
clinicians found most patients received their newly prescribed medications timely.
However, we identified one significant deficiency as follows:
• In case 10, the patient was seen for coughing and wheezing and was
prescribed steroid medication to treat a chronic lung disease flare-up;
however, the patient did not receive his newly ordered medication.
27 Deficiencies occurred in cases 1, 7, 9–11, 21, 41, and 43. Significant deficiencies occurred in cases 10 and 11.
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Chronic Medication Continuity
ISP had mixed performance in chronic medication continuity. Compliance testing
showed patients rarely received their chronic care medications within required time
frames (MIT 7.001, 33.3%), mostly due to the pharmacy not timely filling and dispensing
medications. In contrast, OIG clinicians found most patients received their chronic care
medications timely, but we found room for improvement. The following is an example:
• In case 9, the patient received his blood pressure medication seven days late.
Hospital Discharge Medications
Compliance testing showed patients who returned from off-site hospitals or emergency
rooms sporadically received their medications within required time frames (MIT 7.003,
27.8%). In contrast, OIG clinicians identified only one deficiency related to hospital
discharge medication:
• In case 11, the patient, with a recently diagnosed heart condition, did not
receive his newly prescribed medication to treat inflammation of the heart as
ordered and missed three doses of the medication.
Specialized Medical Housing Medications
Compliance testing showed ISP needed improvement with administering medications
timely when patients were admitted to the outpatient housing unit (MIT 13.003, 44.4%).
OIG clinicians found two significant deficiencies as listed below:
• In case 41, the patient, with a history of acid reflux, was prescribed acid
reflux medication. Nursing staff documented the medication was not given
due to a task duplication; however, we found no documentation the patient
actually received the medication.
• In case 43, the patient with a history of eye surgery received multiple vials of
the same prescribed steroid eye drops within four days.
Transfer Medications
Compliance testing showed ISP staff generally performed well ensuring continuity of
transfer medications. For the most part, patients who transferred into the institution
received their medications within required time frames (MIT 6.003, 75.0%). Patients
transferring from one housing unit to another almost always received their medications
timely (MIT 7.005, 92.0%). ISP performed satisfactorily in administering medication for
patients who were on layover and temporarily housed at ISP (MIT 7.006, 80.0%). ISP
nurses always ensured all patients who transferred out of the institution received a five-
day supply of medications (MIT 6.101, 100%). OIG clinicians also found most patients
transferring into and out of ISP received their medications timely.
Medication Administration
Compliance testing showed nurses always correctly administered TB medications as
prescribed (MIT 9.001, 100%). Nurses also often monitored these patients correctly (MIT
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Cycle 7, Ironwood State Prison | 51
9.002, 81.8%). OIG clinicians did not have any case samples for patients on TB
medications.
Clinician On-Site Inspection
During the on-site inspection, OIG clinicians interviewed the pharmacist-in-charge (PIC)
and nurses. The PIC provided OIG clinicians with detailed responses to medication
related questions identified during the case review process. In addition, we inspected the
medication administration areas and spoke with medication-line LVNs. The medication
administration areas were clean and well organized. The medication nurses were all very
knowledgeable about the medication administration process.
The OIG team attended several huddles during the on-site inspection and observed good
communication among members of each team regarding medication management. The
medication nurses attended clinic huddles daily. Issues discussed included medication
compliance, abnormal blood sugar levels, and medications expiring within three days.
Nurses were expected to address any medication concerns with the provider during the
huddle, or through the electronic health record system message pool. Nurses also
reported calling the provider directly if orders were needed after hours for patients with
abnormal blood sugar levels or elevated blood pressure. Nurses reported having a good
rapport with leadership, pharmacy staff, and custody staff.
Medication Practices and Storage Controls
The institution proficiently stored and secured narcotic medications in all eight
applicable clinic and medication-line locations (MIT 7.101, 100%).
ISP appropriately stored and secured nonnarcotic medications in only four of eight
applicable clinic and medication-line locations (MIT 7.102, 50.0%). In each of the four
locations, we observed one of the following deficiencies: unsanitary medication storage
area; unissued medication not maintained in its original labeled packaging; the
medication area lacking a clearly labeled designated area for medications to be returned
to the pharmacy; and a treatment cart log missing daily security check entries.
Staff kept medications protected from physical, chemical, and temperature
contamination in five of the eight applicable clinic and medication-line locations (MIT
7.103, 62.5%). In three locations, the medication refrigerators were unsanitary.
Additionally, in one of the three locations, staff did not store internal and external
medications separately.
Staff correctly stored valid, unexpired medications in all eight applicable medication-line
locations (MIT 7.104, 100%).
Nurses exercised proper hand hygiene and contamination control protocols in only two of
six applicable locations (MIT 7.105, 33.3%). In four locations, some nurses neglected to
wash or sanitize their hands before donning gloves or before each subsequent regloving.
Staff in all medication preparation and administration areas showed appropriate
administrative controls and protocols when preparing medications for patients (MIT
7.106, 100%).
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Cycle 7, Ironwood State Prison | 52
Staff in five of six applicable medication areas used appropriate administrative controls
and protocols when distributing medications to their patients (MIT 7.107, 83.3%). In one
clinic, medication nurses did not reliably observe patients while they swallowed directly
observed therapy (DOT) medications.28
Pharmacy Protocols
ISP followed general security, organization, and cleanliness management protocols in its
pharmacy (MIT 7.108, 100%).
In its pharmacy, staff did not properly store nonrefrigerated medication (MIT 7.109, zero).
We found medication with compromised packaging.
The institution did not properly store refrigerated or frozen medications in the pharmacy
(MIT 7.110, zero). We found an expired refrigerated medication, and the medication
refrigerator was unsanitary.
The PIC did not appropriately complete monthly inventories of controlled substances in
the institution’s clinic and medication storage areas (MIT 7.111, zero). Specifically, in one
location, the pharmacist assigned to that location did not properly complete a monthly
nonpharmacy licensed medication storage area inspection checklist (CDCR 7477-B) for
the month of January 2025. In another location, the pharmacist assigned to that location
did not complete a medication storage inspection checklist (CDCR 7477) for the month of
July 2024.
We examined 25 pharmacy related medication error reports. The PIC timely or correctly
processed only eight of these 25 reports (MIT 7.112, 32.0%). In six reports, we found one
or more of the following deficiencies: the form’s date was inaccurate; the form was not
initiated timely; the form had no documentation of the PIC’s recommended changes to
correct the medication error; or the form had no documentation of the PIC’s
determination or findings regarding the error. For the remaining 11 reports, the PIC had
not completed a Pharmacy-Related Medication Error Follow-Up form at the time of our
inspection.
Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors also
followed up on any significant medication errors found during compliance testing. We
did not score this test; we provide these results for informational purposes only. At ISP,
the OIG did not find any applicable medication errors (MIT 7.998).
Our compliance team interviewed patients in restricted housing units to determine
whether they had immediate access to their prescribed asthma rescue inhalers or
nitroglycerin medications. All seven patients indicated they had access to their rescue
medications (MIT 7.999).
28 DOT means “directly observed therapy” and refers to dose-by-dose administration of medications by
appropriately licensed health care staff using the highest level of observation during patient ingestion of their
administered medication.
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7, Ironwood State Prison | 54
Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
7 14 4 33.3%
or did the institution follow departmental policy for refusals or no-shows? (7.001)
Did health care staff administer, make available, or deliver new order prescription
18 7 0 72.0%
medications to the patient within the required time frames? (7.002)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 5 13 5 27.8%
required time frames? (7.003)
For patients received from a county jail: Were all medications ordered by the
institution’s reception center provider administered, made available, or delivered to N/A N/A N/A N/A
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
23 2 0 92.0%
continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily housed patient
had an existing medication order, were medications administered or delivered 4 1 0 80.0%
without interruption? (7.006)
All clinical and medication line storage areas for narcotic medications: Does the
institution employ strong medication security controls over narcotic medications 8 0 2 100%
assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution properly secure and store nonnarcotic medications in the assigned 4 4 2 50.0%
storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution keep nonnarcotic medication storage locations free of contamination in 5 3 2 62.5%
the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution safely store nonnarcotic medications that have yet to expire in the 8 0 2 100%
assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ and follow
hand hygiene contamination control protocols during medication preparation and 2 4 4 33.3%
medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 6 0 4 100%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 5 1 4 83.3%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization, and
1 0 0 100%
cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
0 1 0 0
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
0 1 0 0
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
0 1 0 0
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting protocols?
8 17 0 32.0%
(7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the OIG This is a nonscored test. Please see the indicator
find that medication errors were properly identified and reported by the institution?
(7.998) for discussion of this test.
Pharmacy: For Information Purposes Only: Do patients in restricted housing units This is a nonscored test. Please see the indicator
have immediate access to their KOP prescribed rescue inhalers and nitroglycerin
medications? (7.999) for discussion of this test.
Overall percentage (MIT 7): 56.8%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Ironwood State Prison | 55
Table 14. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: If the
patient had an existing medication order upon arrival, were medications 3 1 21 75.0%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the corresponding 9 0 1 100%
transfer-packet required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
12 0 0 100%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 9 2 1 81.8%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 4 5 1 44.4%
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Ironwood State Prison | 56
Recommendations
• Medical and nursing leadership should analyze the root cause(s) of the challenges to staff
ensuring chronic care medications, newly prescribed medications, hospital discharge
medications, and specialized medical housing patients are administered timely and
without interruption. Leadership should implement remedial measures as appropriate.
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Cycle 7, Ironwood State Prison | 57
Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
out patients quickly. The OIG rated this indicator solely according to the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Proficient (91.9%)
ISP performed very well in this indicator. Staff performed outstandingly in administering
TB medications to patients as prescribed, screening patients annually for TB, and
offering patients an influenza vaccine for the most recent influenza season. They
performed very well in offering colorectal cancer screening for patients from ages 45
through 75, and satisfactorily in monitoring patients taking TB medications and offering
immunizations to chronic care patients. These findings are set forth in the table on the
next page. Based on the overall Preventive Services compliance score result, the OIG
rated this indicator proficient.
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Compliance Score Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
12 0 0 100%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 9 2 1 81.8%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
25 0 0 100%
(9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
23 2 0 92.0%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care
7 2 16 77.8%
patients? (9.008)
Are patients at the highest risk of coccidioidomycosis (Valley Fever)
N/A N/A N/A N/A
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 91.9%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care delivered by the
institution’s nurses, including registered nurses (RN), licensed vocational nurses (LVN),
psychiatric technicians (PT), certified nursing assistants (CNA), and medical assistants
(MA). Our clinicians evaluated nurses’ performance in making timely and appropriate
assessments and interventions. We also evaluated the institution’s nurses’ documentation
for accuracy and thoroughness. Clinicians reviewed nursing performance across many
clinical settings and processes, including sick call, outpatient care, care coordination and
management, emergency services, specialized medical housing, hospitalizations,
transfers, specialty services, and medication management. The OIG assessed nursing care
through case review only and performed no compliance testing for this indicator.
When summarizing nursing performance, our clinicians understand that nurses perform
numerous aspects of medical care. As such, specific nursing quality issues are discussed
in other indicators, such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
Case review found ISP’s overall nursing performance was sufficient. Nurses generally
performed appropriate assessments, interventions, and documentation in outpatient
services, emergency services, transfers, hospital returns, specialized medical housing,
specialty services, and medication management. However, OIG clinicians identified
opportunities for improvement in the outpatient setting with nurses performing
thorough assessments, consulting with the provider for abnormal findings in a timely
manner, and with wound care assessment and documentation. Factoring all the
information, the OIG rated this indicator adequate.
Case Review Results
We reviewed 167 nursing encounters in 45 cases. Of the nursing encounters we reviewed,
89 occurred in the outpatient setting, and 12 were sick call requests. We identified 43
overall nursing performance deficiencies, seven of which were significant.29
Outpatient Nursing Assessment and Interventions
A critical component of nursing care is the quality of nursing assessment, which includes
both subjective (patient interviews) and objective (observation and examination) elements.
29 Deficiencies occurred in cases 2, 3, 7, 8, 10, 12–14, 18–20, 22, 23, 26, 29, 31, 34, 39, and 40–43. Significant
deficiencies occurred in cases 3, 12, 13, 20, and 23.
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Nurses generally performed appropriate assessments and interventions. We identified 19
nursing outpatient deficiencies, three of which were significant.30
Nurses triaged sick call requests timely and initiated face-to-face appointments within
policy guidelines and as clinically indicated. We identified a pattern of deficiencies
related to incomplete assessments and nurses not informing the provider of significant
abnormal findings. Although both deficiencies presented opportunities for improvement,
neither significantly impacted the patients’ care. Examples are as follows:
• In case 13, the patient complained of swelling and pain to his lower lip for
two days that started when he began taking antibiotics. However, the sick
call nurse did not recognize a possible allergic reaction and did not report the
abnormal findings to the provider.
• In case 23, the patient complained he could not eat because his blood sugar
levels were too high. He requested changes to his insulin because sometimes
he felt weak. During the nursing encounter, the sick call nurse documented
the patient's morning blood sugar levels were abnormally high for three days
in a row. However, the nurse did not notify the provider of the abnormal
blood sugar levels and instead ordered a provider follow-up in 14 days.
• In case 31, the patient reported receiving treatment for a penis infection
three weeks prior but felt the medication was not helping. The sick call nurse
documented a small amount of thin white discharge and mild redness on the
head of the penis. However, the nurse ordered a provider follow up in 14 days
instead of notifying the provider of the abnormal finding.
Outpatient Nursing Documentation
Complete and accurate nursing documentation is an essential component of patient care.
Without proper documentation, health care staff can overlook changes in patients’
conditions. Nurses generally documented care appropriately.
Wound Care
We reviewed three cases in which nurses documented the patient had a wound. We
identified three deficiencies, none of which were significant.31 All the deficiencies
occurred when nurses either did not assess the wound or did not provide thorough
documentation. An example is listed below:
• In case 14, the patient was ordered to receive daily wound care for a right
thigh incision; however, nursing staff often did not document the details of
the wound care completed, including description of the wound, care
performed to the wound, or dressing change.
30 Deficiencies occurred in cases 2, 3, 8, 10, 12–14, 23, 26, 29, 31, 34, 39, and 40. Significant deficiencies occurred in
cases 13, 23, and 31.
31 Wound care deficiencies occurred in cases 13, 14, and 42.
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Emergency Services
We reviewed 27 urgent or emergent events. Nurses responded promptly to emergent
events. However, their assessments showed room for improvement, which we detail
further in the Emergency Services indicator.
Hospital Returns
We reviewed 20 events involving returns from off-site hospitals or emergency rooms. The
nurses performed good nursing assessments, which we detailed further in the Transfers
indicator.
Transfers
We reviewed three cases involving the transfer-in process. The nurses performed good
assessments, interventions, and documentation. We also reviewed three cases involving
the transfer-out processes. The nurses performed sufficient screenings and
documentation. Please refer to the Transfers indicator for further details.
Specialized Medical Housing
We reviewed 19 nursing events. The nurses generally performed sufficient assessments
and interventions. For more specific details, please refer to the Specialized Medical
Housing indicator.
Specialty Services
We reviewed six cases with a total of 12 events in which patients returned from an off-site
specialty service appointment for specialty procedures or consultations. We identified
two deficiencies, neither of which was significant.32 In both cases, nurses did not perform
an assessment and did not document vital signs. Please refer to the Specialty Services
indicator for additional details.
Medication Management
OIG clinicians reviewed 110 events involving medication management and found most
nurses administered patients’ medications as prescribed. Please refer to the Medication
Management indicator for additional details.
Clinician On-Site Inspection
OIG clinicians interviewed nurse instructors and nurses in the TTA, OHU, R&R,
outpatient clinics, and medication administration areas. We attended organized huddles.
Patient care teams were familiar with their patient populations, and nurses were
knowledgeable about processes in their respective areas. The nurse instructors provided
information regarding updated RN protocol training. They reported all RNs were
provided the RN protocol training.
32 Deficiencies occurred in cases 7 and 13.
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While on site, we met with the Chief Nurse Executive (CNE) and the Director of Nursing
(DON) to discuss our case review findings. They agreed with most findings and were very
organized and prepared for our discussion. Nursing staff generally reported nursing
morale was good. In addition, they described having good rapport with nursing
leadership and custody staff. At the time of our inspection, ISP staff voiced concerns
regarding the recent news of an upcoming prison closure and the possibility of the local
hospital closing.
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Recommendations
• Nursing leadership should analyze the challenges to nurses performing
thorough assessments, consulting with the provider regarding abnormal test
findings in a timely manner, and assessing and documenting wound care
thoroughly. Leadership should implement remedial measures as appropriate.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of care delivered by the
institution’s providers: physicians, physician assistants, and nurse practitioners. Our
clinicians assessed the institution’s providers’ performance in evaluating, diagnosing, and
managing their patients properly. We examined provider performance across several
clinical settings and programs, including sick call, emergency services, outpatient care,
chronic care, specialty services, intake, transfers, hospitalizations, and specialized
medical housing. We assessed provider care through case review only and performed no
compliance testing for this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
Case review found ISP providers generally delivered good care. They made appropriate
assessments and decisions, managed chronic medical conditions effectively, and reviewed
medical records thoroughly. However, providers sometimes either did not generate or
sent incomplete patient test result notification letters. After considering all aspects of
care, the OIG rated this indicator adequate.
Case Review Results
OIG clinicians reviewed 170 medical provider encounters and identified 16 deficiencies,
five of which were significant.33 OIG physicians also rated the overall adequacy of care for
each of the 20 comprehensive case reviews. Of these 20 cases, we rated 18 adequate and
two inadequate.
Outpatient Assessment and Decision-Making
Providers generally made appropriate assessments and sound medical plans for their
patients. OIG clinicians identified one deficiency related to poor assessment:
• In case 15, a provider evaluated the patient, who had prior chest pain and a
recent positive cardiac stress test; however, the provider did not inquire
whether the patient had any cardiac symptoms.
We found two deficiencies related to lack of pertinent physical examinations.34 An
example follows:
33 Deficiencies occurred in cases 2, 7, 15, 41, 42, 43, and 44. Significant deficiencies occurred in cases 15, 42, 43,
and 44.
34 Deficiencies occurred in cases 7 and 44.
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• In case 7, a provider evaluated the patient for groin rash and prescribed an
antifungal cream; however, the provider did not perform a skin or groin
exam.
Providers generally diagnosed medical conditions correctly, ordered appropriate tests,
and coordinated effective treatment plans for their patients. OIG clinicians identified one
deficiency related to lack of a medical plan:
• In case 7, a provider evaluated the patient for a recent colonoscopy showing
large internal, and moderate-sized external, hemorrhoids; however, the
provider did not formulate a plan for the management of the hemorrhoids.
Outpatient Review of Records
Providers performed satisfactorily in reviewing hospital records and addressing the
hospitalists’ recommendations. ISP providers also reviewed diagnostic tests on time and
addressed abnormal results appropriately. However, OIG clinicians identified two
deficiencies related to insufficiently addressed abnormal laboratory results:
• In case 7, a provider endorsed a positive fecal immunochemical test that was
suggestive for possible blood in the stool, which can be an early sign of
gastrointestinal bleed or cancer. However, the provider did not have the
patient follow up urgently to assess for signs and symptoms of possible
gastrointestinal bleed.
• In case 44, a provider assessed the patient for elevated bilirubin level but did
not formulate a diagnosis or differential diagnoses for the cause of elevated
bilirubin and did not document plan to recheck the bilirubin level.35
Providers generally performed well in reviewing medical records for patients transferring
into the institution and ordered diagnostic tests and specialty appointments as medically
indicated.
Providers also performed well in reviewing the medication administration record (MAR)
and renewing patients’ medications timely. However, we identified one deficiency related
to delayed renewal of a chronic care medication:
• In case 15, the patient had Barrett’s esophagitis and required a daily proton
pump inhibitor, which decreases stomach acid, helps prevent further damage
to the esophagus, and potentially lowers the risk of developing esophageal
cancer.36 The provider allowed the medication to expire, and the medication
was not renewed until two and a half months later.
35 Bilirubin is a yellow colored substance produced when red blood cells are broken down and processed by the
liver.
36 Barrett’s esophagitis is a medical condition where the lining of the lower esophagitis has cellular changes due
to acid reflux from the stomach. Without treatment, Barrett’s esophagitis may progress to esophageal cancer.
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Emergency Care
Providers generally made appropriate triage decisions and treatment plans for patients
needing emergency care in the triage and treatment area (TTA). Providers also usually
documented required progress notes for TTA events.
Chronic Care
Providers performed well in managing chronic medical conditions such as hypertension,
diabetes, asthma, hepatitis C infection, and cardiovascular disease. For patients with
diabetes, the providers regularly monitored the patients’ blood glucose levels and
adjusted diabetic medications as indicated.
For patients with cardiovascular disease, the providers prescribed aspirin and cholesterol
lowering medications to reduce the risk of heart attack or stroke.
Specialty Services
ISP providers appropriately referred patients to specialists and reviewed specialty reports
in a timely manner. Providers also addressed most specialists’ recommendations timely.
OIG clinicians identified one deficiency related to not addressing a specialist’s
recommendation. We discuss this further in the Specialty Services indicator.
Outpatient Documentation Quality
Providers generally recorded outpatient encounters on the same day of the encounter and
documented reasonings for prescribing medications or ordering diagnostic tests. OIG
clinicians identified one deficiency related to not documenting a progress note.
• In case 41, the patient’s record contained an order for x-rays of cervical spine
and left scapula; however, we found no provider documentation of the
medical rationale for the x-rays.
Patient Notification Letter
Providers generally sent patient letters to thoroughly communicate diagnostic test results
with their patients. However, OIG clinicians identified 16 deficiencies related to missing
or incomplete patient test results notification letters. We discussed these deficiencies
further in the Diagnostic Services and Health Information Management indicators.
Clinician On-Site Inspection
At the time of the OIG inspection, ISP had three on-site providers and two telemedicine
providers. Leadership reported plans to add one and a half provider positions in three
months and noted ISP would then be fully staffed for providers. Providers expressed
enthusiasm about their work and general satisfaction with nursing, diagnostic, and
specialty services.
The OIG clinician attended the daily morning provider meeting where providers
discussed patients who returned from specialty appointments or hospital and significant
TTA events. Medical leadership reported conducting weekly provider meetings, which
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occurs every Thursday. In these meetings, the Chief Physician and Surgeon discussed
new policies and trainings.
OIG clinicians attended two organized clinic morning huddles which were well attended
by the patient care teams. The clinic teams discussed specialty appointments with
recommendations, patients’ glucose logs, hospital returns, and medication refusals. The
nurses informed the providers of the scheduled clinic appointments, expiring
medications, and new arrivals from other institutions.
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Recommendations
The OIG offers no recommendations for this indicator.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing,
monitoring, and intervening for medically complex patients requiring close medical
supervision. Our inspectors also evaluated the timeliness and quality of provider and
nursing intake assessments and care plans. We assessed staff members’ performance in
responding promptly when patients’ conditions deteriorated and looked for good
communication when staff consulted with one another while providing continuity of care.
At the time of our inspection, ISP’s specialized medical housing consisted of an
outpatient housing unit (OHU).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (81.1%)
OIG clinicians found ISP performed satisfactorily in this indicator. The providers
performed timely admission history and physical examinations. Providers and nurses
generally provided good care. However, we identified a pattern of deficiencies in
incomplete nursing assessments and documentation. Considering all factors, the OIG
rated the case review component of this indicator adequate.
Compliance testing showed mixed results in this indicator. Nursing staff performed very
well in completing initial assessments. Providers performed well in completing history
and physical examinations within required time frames. However, nursing staff needed
significant improvement in ensuring medication continuity for patients newly admitted
to the specialized medical housing unit. Based on the overall Specialized Medical
Housing compliance score result, the OIG rated the compliance testing component of
this indicator adequate.
Case Review and Compliance Testing Results
We reviewed six OHU cases that included 22 provider events and 19 nursing events. Due
to the frequency of nursing and provider contacts in the specialized medical housing, we
bundle up to two weeks of patient care into a single event. We identified 15 deficiencies,
two of which were significant.37
Provider Performance
Compliance testing showed providers generally performed admission history and
physical (H&P) examinations timely (MIT 13.002, 90.0%). OIG clinicians found providers
completed all admission H&P examinations timely. However, OIG clinicians identified
one missed discharge summary as follows:
37 Deficiencies occurred in cases 41, 42 and 43. Significant deficiencies occurred in cases 42 and 43.
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• In case 42, the OHU provider discharged a patient from the OHU but did not
complete a discharge summary.
The providers mostly rounded on their patients at clinically appropriate intervals and
documented their progress notes thoroughly. OIG clinicians identified one missed
documentation:
• In case 41, the OHU provider did not document the reasoning for x-rays of
cervical spine and left scapula.
The providers reviewed off-site specialty service reports timely and generally made
appropriate diagnoses and medical decisions. Our clinicians identified one deficiency,
and we discussed in the Specialty Services indicator.
Nursing Performance
Compliance testing showed OHU nurses performed timely admission assessments most
of the time (MIT 13.001, 90.0%). The OIG clinicians reviewed 19 nursing events and
identified nine deficiencies, none of which were significant.38 We found OHU nurses
conducted rounds appropriately and generally provided good care. However, we
identified a pattern of deficiencies for incomplete nursing assessments and
documentation. The following cases are examples:
• In case 42, a patient was admitted to the OHU for wound care after having a
painful cyst removed from the buttock. During his stay, OHU nurses
frequently documented wound care was performed, but often did not
document the details of the wound care completed, including a description of
the wound, care performed, or dressing change details.
• In case 43, the patient was admitted to the OHU due to a macular hole repair
in his left eye. However, nursing staff did not always assess the patient’s left
eye. In addition, when the patient was discharged from the OHU, nurses did
not complete the nursing discharge summary and did not educate the
patient.
Medication Administration
Compliance testing showed patients admitted to the OHU only sporadically received
their medications timely (MIT 13.003, 44.4%). In contrast, OIG clinicians identified only
two deficiencies, which are detailed further in the Medication Management indicator.
Clinician On-Site Inspection
The OHU had 14 medical beds, five of which were negative-pressure rooms for
respiratory isolation. At the time of our inspection, four beds were occupied.
At ISP’s OHU, OIG clinicians interviewed the OHU nurse. The nurse reported the OHU
had 24-hour nursing staff with one RN assigned during business hours and an LVN
assigned during the afternoon and night shift. The nurse reported the OHU nurses are
38 Deficiencies occurred in cases 41, 42, and 43.
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expected to complete a daily assessment and round every two hours. In addition, the
nurse reported TTA RNs were assigned to complete admissions and discharges, as well as
help the LVNs as needed. The OHU had a designated OHU provider, who completed
rounds with nursing staff.
The clinicians attended the morning huddle in the OHU. The huddle participants joined
via Microsoft Teams online video meeting and included all yard office technicians, off-
site and on-site specialty staff, the utilization management RN, TTA RNs, OHU nursing
staff and supervisors, the OHU provider, the pharmacist, the dental supervisor, and the
Chief Physician and Surgeon. The OHU RN discussed all the currently admitted patients
and followed the huddle script. The huddle was well organized, and staff participation
was good.
We met with nursing leadership to discuss some of our case review findings, which
showed a pattern of incomplete or missing documentation for patients who had
discharged from the OHU. The Chief Nurse Executive informed us changes had been
made to the OHU local operating procedure to include the patient departing process
workflow and stated instructions had been emailed to staff.
Compliance On-site Inspection and Discussion
At the time of on-site inspection, the OHU had a functional call light communication
system (MIT 13.101, 100%).
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Compliance Score Results
Table 16. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Did the registered nurse complete an initial
9 1 0 90.0%
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
9 1 0 90.0%
required time frame? (13.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 4 5 1 44.4%
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call 1 0 0 100.0%
system? (13.101)
For specialized health care housing (CTC, SNF, hospice, OHU): Do health
care staff perform patient safety checks according to institution’s local 0 0 1 N/A
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): 81.1%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should develop strategies to ensure specialized medical housing
nursing staff perform thorough patient assessments and documentation and should
implement remedial measures as appropriate.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. The OIG
clinicians focused on the institution’s performance in providing needed specialty care.
Our clinicians also examined specialty appointment scheduling, providers’ specialty
referrals, and medical staff’s retrieval, review, and implementation of any specialty
recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Proficient Adequate (84.2%)
OIG clinicians found ISP performed very well in this indicator. All specialty
appointments were completed as requested, and staff timely retrieved and scanned all
specialty reports; however, we identified rare late endorsements. Overall, the OIG rated
the case review component of this indicator proficient.
Compliance testing showed mixed results in this indicator. Depending on the priority of
the specialty service, access ranged from needing improvement to excellent. Preapproved
specialty services for newly arrived patients generally occurred within required time
frames. Performance in retrieving specialty reports and prompt provider endorsements
ranged from satisfactory to excellent. Based on the overall Specialty Services compliance
score result, the OIG rated the compliance testing component of this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 106 events related to specialty services and identified four
deficiencies in this category; none of which were significant.39
Access to Specialty Services
Compliance testing revealed variable timely completion of initial high-priority (MIT
14.001, 66.7%), initial medium-priority (MIT 14.004, 73.3%), and initial routine-priority
(MIT 14.007, 100%) specialty appointments. Staff completed most follow-up specialty
appointments timely (MIT 14.003, 75.0%, MIT 14.006, 81.8%, and MIT 14.009, 87.5%). For
patients who transferred to ISP with preapproved specialty requests, compliance testing
showed most specialty appointments occurred timely (MIT 14.010, 85.0%). In contrast,
OIG clinicians found all specialty appointments including preapproved specialty requests
occurred within required time frames.
Provider Performance
OIG clinicians also found ISP providers delivered exceptional on-site specialty care,
primarily in the area of medication assisted treatment (MAT) for substance use disorders.
39 Deficiencies occurred in cases 4, 7, and 13.
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Providers referred patients to specialists appropriately and addressed specialists’
recommendations timely. OIG clinicians identified only one deficiency wherein the
provider did not properly address the specialist’s recommendations, as described below:
• In case 43, the OHU provider reviewed a rheumatology consultation but did
not address the rheumatologist’s recommendations to continue an anti-
rheumatic drug and to order physical therapy for the left elbow. The provider
did not document a medical rationale for not following the specialist’s
recommendations.
Nursing Performance
Overall, ISP nurses provided good care related to specialty services. TTA nurses assessed
patients appropriately after return from off-site specialty appointments. TTA and
telemedicine nurses generally documented accurately and ordered provider follow-up
appointments within required time frames. OIG clinicians identified two deficiencies
related to incomplete nursing assessments.40 An example follows:
• In case 7, a nurse assessed a patient who returned from an off-site cardiology
appointment but did not obtain vital signs or perform a cardiovascular
examination.
Health Information Management
Compliance testing showed ISP staff retrieved and scanned almost all specialty
documents within required time frames (MIT 4.002, 93.3%). In addition, ISP’s receipt of,
and the providers’ performance with timely endorsing, high-priority (MIT 14.002, 100%),
medium-priority (MIT 14.005, 86.7%), and routine-priority (MIT 14.008, 80.0%) specialty
reports ranged from excellent to satisfactory. OIG clinicians found ISP staff retrieved and
scanned all specialty reports within required time frames. However, we identified two
deficiencies related to late endorsements.41 One example follows:
• In case 4, staff scanned an ophthalmology specialty report into EHRS;
however, the provider endorsed the consultation report five days late.42
Clinician On-Site Inspection
On-site specialty, off-site specialty, telemedicine specialty, and utilization management
staff coordinated and scheduled specialty appointments at ISP. At the time of our on-site
inspection, leadership reported no ISP staff shortage related to specialty services.
ISP has on-site specialty services for orthotics, optometry, general surgery, audiology, and
sleep study. ISP staff coordinated all on-site specialty appointments, whereas CCHCS
headquarters staff coordinated all telemedicine specialty appointments. ISP relied on
multiple medical centers for off-site specialty appointments. Some medical centers were
40 Deficiencies occurred in cases 7 and 13.
41 Deficiencies occurred in cases 4 and 7.
42 EHRS is the Electronic Health Records System. The department’s electronic health record system is used for
storing the patient’s medical history. The health care staff use the system to communicate. This record stays
with the patient throughout the patient’s time in department’s correctional system.
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located in San Diego, about 200 miles away. At the time of the on-site inspection, ISP
reported having a backlog of five specialty appointments.
The specialty services supervisor reported specialty nurses utilized a tracking tool for
completing specialty appointments and retrieving specialists’ reports. She discussed
experiencing challenges in retrieving specialists’ reports from medical centers and
hospitals in which ISP staff lacked access to the electronic medical records. ISP staff had
to fax requests for specialty reports. To ensure timely provider endorsements, after
scanning the specialty reports into the EHRS, specialty staff would message providers to
review and sign the reports.
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Compliance Score Results
Table 17. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within 14 calendar
days of the primary care provider order or the Physician Request for 10 5 0 66.7%
Service? (14.001)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 14 0 1 100%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 9 3 3 75.0%
(14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or Physician Request for 11 4 0 73.3%
Service? (14.004)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 13 2 0 86.7%
frame? (14.005)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 9 2 4 81.8%
(14.006)
Did the patient receive the routine-priority specialty service within 90
calendar days of the primary care provider order or Physician Request for 15 0 0 100%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 12 3 0 80.0%
frame? (14.008)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 7 1 7 87.5%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
17 3 0 85.0%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Did the institution deny the primary care provider’s request for specialty
4 0 0 100%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
3 1 0 75.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 84.2%
Source: The Office of the Inspector General medical inspection results.
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Table 18. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up visits
40 3 2 93.0%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
28 2 15 93.3%
within five calendar days of the encounter date? (4.002)
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the root cause(s) of challenges to the
timely provision of high- and medium-priority specialty appointments and
should implement remedial measures as appropriate.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care administrative
processes. Our inspectors examined the timeliness of the medical grievance process and
checked whether the institution followed reporting requirements for adverse or sentinel
events and patient deaths. Inspectors checked whether the Emergency Medical Response
Review Committee (EMRRC) met and reviewed incident packages. We investigated and
determined whether the institution conducted required emergency response drills.
Inspectors also assessed whether the Quality Management Committee (QMC) met
regularly and addressed program performance adequately. In addition, our inspectors
determined whether the institution provided training and job performance reviews for its
employees. We checked whether staff possessed current, valid professional licenses,
certifications, and credentials. The OIG rated this indicator solely based on the
compliance score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (71.5%)
ISP’s performance was mixed in this indicator. While ISP scored exceptionally in several
applicable tests, it needed improvement in some areas. The EMRRC only intermittently
completed the required checklists. In addition, physician managers did not complete all
annual performance appraisals in a timely manner, and the nurse educator did not ensure
all newly hired nurses received required onboarding training. Lastly, ISP’s pharmacy
Drug Enforcement Agency (DEA) registration certificate had a six-day renewal lapse
during our testing period. These findings are set forth in the table on the next page.
Based on the overall Administrative Operations compliance score, the OIG rated the
compliance testing component of this indicator inadequate.
Compliance Testing Results
Nonscored Results
At ISP, the OIG did not have any applicable adverse sentinel events requiring root cause
analysis during our inspection period (MIT 15.001).
We obtained CCHCS Mortality Case Review reporting data. In our inspection, for two
patients, we found no evidence in the submitted documentation indicating the
preliminary mortality reports had been completed. These reports were overdue at the
time of OIG’s inspection (MIT 15.998).
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Scored Results
In addition to the above findings, OIG compliance inspectors found the following during
our on-site inspection:
• ISP’s pharmacy did not maintain a valid Drug Enforcement Agency (DEA)
registration certificate during our testing period. As a result, ISP scored zero
(MIT 15.109, zero). The renewal had a six-day lapse between November 30,
2023, and December 6, 2023. Upon inquiry, CCHCS reported the following:
The delay was due to an improper hand off during a staffing change of the
PIC. The outgoing PIC separated on October 9, 2023, and a new pharmacist
assumed the PIC positions for both ISP and its neighboring institution,
Chuckawalla Valley State Prison (CVSP), on October 10, 2023. The new PIC
was instructed to renew the DEA license after filing the required Board of
Pharmacy Notification Change of PIC on October 11, 2023. However, the
new PIC did not renew the license by the deadline. CCHCS was only notified
on December 4, 2023, and they issued emergency guidance. With the
assistance of the Pharmacy HQ and Regional office, documentation showed
the ISP Pharmacy DEA license renewal was issued on December 6, 2023. At
the time of our inspection, the PIC reported medication distribution and
administration continued, and the PIC was in constant communication with
the Board of Pharmacy. CCHCS reported taking immediate mitigation efforts
described above when made aware of the lapse. However, when OIG
compliance inspectors asked about documentation of communication, the
PIC could not provide any evidence.
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Compliance Score Results
Table 19. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the This is a nonscored test. Please refer to the
institution meet RCA reporting requirements? (15.001) discussion in this indicator.
Did the institution’s Quality Management Committee (QMC) meet monthly?
6 0 0 100%
(15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
7 5 0 58.3%
packages the committee reviewed include the required documents?
(15.003)
For institutions with licensed care facilities: Did the Local Governing Body
(LGB) or its equivalent meet quarterly and discuss local operating N/A N/A N/A N/A
procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during each
watch of the most recent quarter, and did health care and custody staff 3 0 0 100%
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
2 0 0 100%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
0 2 1 0
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 11 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 6 0 1 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 0 1 0 0
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
0 1 0 0
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG medical This is a nonscored test. Please refer to Table 3
inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 71.5%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to review
CCHCS policies and procedures, relevant court orders, and guidance developed by the
American Correctional Association. We also reviewed professional literature on
correctional medical care; reviewed standardized performance measures used by the
health care industry; consulted with clinical experts; and met with stakeholders from the
court, the receiver’s office, the department, the Office of the Attorney General, and the
Prison Law Office to discuss the nature and scope of our inspection program. With input
from these stakeholders, the OIG developed a medical inspection program that evaluates
the delivery of medical care by combining clinical case reviews of patient files, objective
tests of compliance with policies and procedures, and an analysis of outcomes for certain
population-based metrics.
We rate each of the quality indicators applicable to the institution under inspection based
on case reviews conducted by our clinicians or compliance tests conducted by our
registered nurses. Figure A–1 below depicts the intersection of case review and
compliance.
Figure A–1. Inspection Indicator Review Distribution for ISP
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of
its stakeholders, which continues in the Cycle 7 medical inspections. Below, Table A–1
provides important definitions that describe this process.
Table A–1. Case Review Definitions
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The OIG eliminates case review selection bias by sampling using a rigid methodology. No
case reviewer selects the samples he or she reviews. Because the case reviewers are
excluded from sample selection, there is no possibility of selection bias. Instead,
nonclinical analysts use a standardized sampling methodology to select most of the case
review samples. A randomizer is used when applicable.
For most basic institutions, the OIG samples 20 comprehensive physician review cases.
For institutions with larger high-risk populations, 25 cases are sampled. For the
California Health Care Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected institution and
from CCHCS. Our analysts then apply filters to identify clinically complex patients with
the highest need for medical services. These filters include patients classified by CCHCS
with high medical risk, patients requiring hospitalization or emergency medical services,
patients arriving from a county jail, patients transferring to and from other departmental
institutions, patients with uncontrolled diabetes or uncontrolled anticoagulation levels,
patients requiring specialty services or who died or experienced a sentinel event
(unexpected occurrences resulting in high risk of, or actual, death or serious injury),
patients requiring specialized medical housing placement, patients requesting medical
care through the sick call process, and patients requiring prenatal or postpartum care.
After applying filters, analysts follow a predetermined protocol and select samples for
clinicians to review. Our physician and nurse reviewers test the samples by performing
comprehensive or focused case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the clinicians review
medical records, they record pertinent interactions between the patient and the health
care system. We refer to these interactions as case review events. Our clinicians also
record medical errors, which we refer to as case review deficiencies.
Deficiencies can be minor or significant, depending on the severity of the deficiency. If a
deficiency caused serious patient harm, we classify the error as an adverse event. On the
next page, Figure A–2 depicts the possibilities that can lead to these different events.
After the clinician inspectors review all the cases, they analyze the deficiencies, then
summarize their findings in one or more of the health care indicators in this report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and compliance
inspectors. Analysts follow a detailed selection methodology. For most compliance
questions, we use sample sizes of approximately 25 to 30. Figure A–3 below depicts the
relationships and activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT) questions to
determine the institution’s compliance with CCHCS policies and procedures. Our nurse
inspectors assign a Yes or a No answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain information,
allowing them to answer most of the MIT questions. Our regional nurses visit and
inspect each institution. They interview health care staff, observe medical processes, test
the facilities and clinics, review employee records, logs, medical grievances, death
reports, and other documents, and obtain information regarding plant infrastructure and
local operating procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for each of the
questions applicable to a particular indicator, then averages the scores. The OIG
continues to rate these indicators based on the average compliance score using the
following descriptors: proficient (85.0 percent or greater), adequate (between 84.9 percent
and 75.0 percent), or inadequate (less than 75.0 percent).
Indicator Ratings and the Overall Medical Quality Rating
The OIG medical inspection unit individually examines all the case review and
compliance inspection findings under each specific methodology. We analyze the case
review and compliance testing results for each indicator and determine separate overall
indicator ratings. After considering all the findings of each of the relevant indicators, our
medical inspectors individually determine the institution’s overall case review and
compliance ratings.
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Appendix B: Case Review Data
Table B–1. ISP Case Review Sample Sets
Sample Set Total
CTC/OHU 3
Death Review/Sentinel Events 1
Diabetes 5
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 18
Specialty Services 4
47
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Table B–2. ISP Case Review Chronic Care Diagnoses
Diagnosis Total
Anemia 3
Arthritis/Degenerative Joint Disease 7
Asthma 5
COPD 1
COVID-19 3
Cancer 1
Cardiovascular Disease 1
Chronic Kidney Disease 4
Chronic Pain 8
Cirrhosis/End Stage Liver Disease 2
DVT/PE 1
Diabetes 15
Gastroesophageal Reflux Disease 10
Hepatitis C 8
Hyperlipidemia 20
Hypertension 16
Mental Health 4
Rheumatological Disease 1
Seizure Disorder 1
Sleep Apnea 1
Substance Abuse 13
Thyroid Disease 1
126
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Table B–3. ISP Case Review Events by Program
Program Total
Diagnostic Services 108
Emergency Care 42
Hospitalization 33
Intrasystem Transfers In 6
Intrasystem Transfers Out 6
Outpatient Care 375
Specialized Medical Housing 61
Specialty Services 116
747
Table B–4. ISP Case Review Sample Summary
Total
MD Reviews Detailed 20
MD Reviews Focused 3
RN Reviews Detailed 11
RN Reviews Focused 27
Total Reviews 61
Total Unique Cases 47
Overlapping Reviews (MD & RN) 14
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Appendix C: Compliance Sampling Methodology
Ironwood State Prison
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least one
Patients condition per patient — any risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 30 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 23 OIG Q: 4.005 • See Health Information Management
Community (Medical Records) (returns from
Hospital community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001 – 003 Radiology 10 Radiology Logs • Appointment date
(90 days – 9 months)
• Randomize
• Abnormal
MITs 2.004 – 006 Laboratory 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 0 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 30 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 23 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 23 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 10 OIG inspector • Identify and inspect all on-site clinical
MITs 5.107 – 111 on-site review areas
Transfers
MITs 6.001 – 003 Intrasystem Transfers 25 SOMS • Arrival date (3 – 9 months)
• Arrived from (another departmental
facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 10 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 • See Access to Care
Medication • At least one condition per patient —
any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of IPs tested in
MIT 7.001
MIT 7.003 Returns From 23 OIG Q: 4.005 • See Health Information Management
Community Hospital (Medical Records) (returns from
community hospital)
MIT 7.004 RC Arrivals — N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 5 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies OIG inspector • Identify and inspect clinical & med
Areas by test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site clinical
Preparation and by test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 10 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 25 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit 7 On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications medication listing medications for IPs housed in
restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001 – 007 Recent Deliveries N/A at this OB Roster • Delivery date (2 – 12 months)
institution • Most recent deliveries (within date
range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2 – 12 months)
institution • Earliest arrivals (within date range)
Preventive Services
MITs 9.001 – 002 TB Medications 12 Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months
or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever N/A at this Cocci transfer • Reports from past 2 – 8 months
institution status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 007 RC N/A at this SOMS • Arrival date (2 – 8 months)
institution • Arrived from (county jail, return from
parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001 – 003 Specialized Health 10 CADDIS • Admit date (2 – 8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
• Rx count
• Randomize
MITs 13.101 – 102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care / addiction
medication, narcotic treatment
program, and transgender services
• Randomize
MITs 14.004 – 006 Medium-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care/addiction
medication, narcotic treatment
program, and transgender services
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Specialty Services (continued)
MITs 14.007 – 009 Routine-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care/addiction
medication, narcotic treatment
program, and transgender services
• Randomize
MIT 14.010 Specialty Services 20 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 4 InterQual • Review date (3 – 9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events events report (2 – 8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 12 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB N/A at this LGB meeting • Quarterly meeting minutes
institution minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
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Quality Sample Category No. of Data Source Filters
Indicator Samples
Administrative Operations (continued)
MIT 15.103 Death Reports 2 Institution-list of • Most recent 10 deaths
deaths in prior Initial death reports
12 months
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 3 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 11 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site certification • All staff
Response tracking logs • Providers (ACLS)
Certifications • Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
MIT 15.109 Pharmacy and All On-site listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
document
MIT 15.110 Nursing Staff New All Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998 CCHCS Mortality 2 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
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California Correctional Health Care Services’
Response
January 20, 2026
Amarik Singh, Inspector General
Office of the Inspector General
10111 Old Placerville Road, Suite 110
Sacramento, CA 95827
Dear Ms. Singh:
California Correctional Health Care Services has reviewed the draft Medical Inspection Report
for Ironwood State Prison conducted by the Office of the Inspector General from June 2024 to
November 2024. Thank you for preparing the report.
If you have any questions or concerns, please contact me at (916) 691-3747.
Sincerely,
DeAnna Gouldy
Deputy Director
Policy and Risk Management Services
California Correctional Health Care Services
cc: Diana Toche, D.D.S., Undersecretary, Health Care Services, CDCR
Clark Kelso, Receiver
Jeff Macomber, Secretary, CDCR
Directors, CCHCS
Sarah Hartmann, Chief Counsel, CCHCS Office of Legal Affairs
Renee Kanan, M.D., Deputy Director, Medical Services, CCHCS
Barbara Barney-Knox, R.N., Deputy Director, Nursing Services, CCHCS
Annette Lambert, Deputy Director, Quality Management, CCHCS
Rainbow Brockenborough, Deputy Director, Institution Operations, CCHCS
Robin Hart, Associate Director, Risk Management Branch, CCHCS
Regional Executives, Region (XX), CCHCS
Chief Executive Officer, INST
Heather Pool, Chief Assistant Inspector General, OIG
Doreen Pagaran, R.N., Nurse Consultant Program Review, OIG
Amanda Elhardt, Report Coordinator, OIG
P.O. Box 588500
Elk Grove, CA 95758
Office of the Inspector General, State of California Inspection Period: June 2024 – November 2024 Report Issued: January 2026
Cycle 7
Medical Inspection Report
for
Ironwood State Prison
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Shaun Spillane
Chief Deputy Inspector General
STATE of CALIFORNIA
January 2026
OIG