OIG
Mule Creek State Prison Cycle 7 Medical Inspection Report
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Cycle 7, Mule Creek 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 11
Indicators 13
Access to Care 13
Diagnostic Services 19
Emergency Services 23
Health Information Management 27
Health Care Environment 33
Transfers 42
Medication Management 49
Preventive Services 57
Nursing Performance 60
Provider Performance 65
Specialized Medical Housing 71
Specialty Services 74
Administrative Operations 80
Appendix A: Methodology 83
Case Reviews 84
Compliance Testing 87
Indicator Ratings and the Overall Medical Quality Rating 88
Appendix B: Case Review Data 89
Appendix C: Compliance Sampling Methodology 93
California Correctional Health Care Services’ Response 101
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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Illustrations
Tables
1. MCSP Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. MCSP Master Registry Data as of September 2024 7
3. MCSP Health Care Staffing Resources as of September 2024 8
4. MCSP Results Compared With State HEDIS Scores 10
5. Access to Care 16
6. Other Tests Related to Access to Care 17
7. Diagnostic Services 21
8. Health Information Management 30
9. Other Tests Related to Health Information Management 31
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 72
17. Specialty Services 77
18. Other Tests Related to Specialty Services 78
19. Administrative Operations 81
A–1. Case Review Definitions 84
B–1. MCSP Case Review Sample Sets 89
B–2. MCSP Case Review Chronic Care Diagnoses 90
B–3. MCSP Case Review Events by Program 91
B–4. MCSP Case Review Sample Summary 91
Figures
A–1. Inspection Indicator Review Distribution for MCSP 83
A–2. Case Review Testing 86
A–3. Compliance Sampling Methodology 87
Photographs
1. Indoor Patient Waiting Area 33
2. Vital Signs and Blood Draw Stations Were Located Next to Each Other 34
3. Medical Supply Stored With Medications 35
4. Long-Term Storage of Staff Members’ Food in the Medical Supply
Storage Room 36
5. Expired Medical Supply Dated August 2024 36
6. Medical Supply’s Manufacturer Required Storage Temperature Set
Between 59°F and 77°F 37
7. Medical Supply Stored Beyond Manufacturer’s Temperature Guidelines 37
8. Insect in the Health-Care Area 38
9. Insect in the Health-Care Area 38
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care the department provides to
its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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As we did during Cycle 6, our office continues to inspect both those institutions
remaining under federal receivership and those delegated back to the department. There
is no difference in the standards used for assessing a delegated institution versus an
institution not yet delegated. At the time of the Cycle 7 inspection of Mule Creek State
Prison (MCSP), 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 February 2024 to July 2024.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between October 2023 and June 2024, emergency services cardiopulmonary resuscitation
reviews between November 2023 and June 2024.
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Summary: Ratings and Scores
We completed the Cycle 7 inspection of MCSP in February 2025. OIG inspectors
monitored the institution’s delivery of medical care that occurred between February 2024
and July 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 MCSP adequate. quality at MCSP adequate.
OIG case review clinicians (a team of physicians and nurse consultants) reviewed 64
cases, which contained 945 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 February 2025
to verify their initial findings. OIG physicians rated the quality of care for 25
comprehensive case reviews. Of these 25 cases, our physicians rated 24 adequate, and one
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 401 patient records and 1,180 data points,
and we used the data to answer 86 policy questions. In addition, we observed MCSP’s
processes during an on-site inspection in September 2024.
The OIG then considered the results from both case review and compliance testing, and
drew overall conclusions, which we report in 12 health care indicators.5
5 The indicators for Reception Center and Prenatal and Postpartum Care did not apply to MCSP. During the
OIG’s Cycle 7 inspection period, Specialized Medical Housing was not sampled or tested.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. MCSP Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies can be
minor or significant, depending on the severity of the deficiency. An adverse event occurs
when the deficiency caused harm to the patient. All major health care organizations
identify and track adverse events. We identify deficiencies and adverse events to
highlight concerns regarding the provision of care and for the benefit of the institution’s
quality improvement program to provide an impetus for improvement.6
The OIG found no adverse events at MCSP during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed nine of the 12
indicators applicable to MCSP. Of these nine indicators, OIG clinicians rated eight
adequate and one inadequate. The OIG physicians also rated the overall adequacy of care
for each of the 25 detailed case reviews they conducted. Of these 25 cases, 24 were
adequate and one was inadequate. In the 945 events reviewed, we identified 196
deficiencies, 37 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 MCSP:
• Patients received excellent access to providers and nurses.
• Staff performed excellently in completing diagnostic tests within requested
time frames.
• Staff received and scanned hospital discharge reports timely.
• Providers delivered excellent care for patients with urgent or emergent
conditions.
• Health care leadership performed well in completing clinical reviews for
unscheduled emergency transports to a higher level of care.
Our clinicians found the following weaknesses at MCSP:
• Providers needed improvement in communicating test results to patients
with complete test result notification letters.
• An on-site specialist did not consistently forward their specialty reports to
providers.
6 For a further discussion of an adverse event, see Table A–1.
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• Staff needed improvement in ensuring they timely contacted emergency
medical services for emergency events.
• MCSP had challenges with chronic care medications and hospital discharge
medications.
Compliance Testing Results
Our compliance inspectors assessed nine of the 12 indicators applicable to MCSP. Of
these nine indicators, our compliance inspectors rated three 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.
MCSP showed a high rate of policy compliance in the following areas:
• Staff ensured patients received diagnostic services within ordered time
frames, and providers timely reviewed and endorsed results.
• Staff performed well in scanning health care services requests and
community hospital discharge reports into patients’ electronic medical
records.
• MCSP provided patients with high-priority, medium-priority, and routine-
priority specialty appointments within required time frames. In addition,
providers reviewed the resulting specialist reports timely.
• Nurses reviewed health care services request forms and conducted face-to-
face encounters within required time frames.
MCSP revealed a low rate of policy compliance in the following areas:
• Staff frequently did not maintain medication continuity for chronic care
patients or patients discharged from the hospital. In addition, MCSP
maintained poor medication continuity for patients who transferred into the
institution.
• Health care staff did not consistently follow universal hand hygiene
precautions during patient encounters.
• Nurses did not regularly inspect emergency medical response bags.
• Medical clinics stored expired medical supplies.
Institution-Specific Metrics
Mule Creek State Prison (MCSP) is located in Ione in Amador County. MCSP operates six
clinics where staff members handle non-urgent requests for medical services, including
five facility clinics and a specialty clinic. MCSP also conducts health screenings in its
receiving and release clinical area (R&R), treats patients requiring urgent or emergent
care in its triage and treatment area (TTA), and treats patients in need of inpatient health
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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services in its correctional treatment center (CTC). MCSP has been designated as an
intermediate care institution. These institutions are predominantly located in or near
urban areas, close to tertiary care centers and specialty care providers for the most cost-
effective care.
As of May 21, 2025, the department reported on its public tracker 85 percent of MCSP’s
incarcerated population was fully vaccinated for COVID-19 while 57 percent of MCSP’s
staff was fully vaccinated for COVID-19.7
On September 3, 2024, the Health Care Services Master Registry showed MCSP had a
total population of 4,063. A breakdown of the medical risk level of the MCSP population
as determined by the department is set forth in Table 2 below.8
Table 2. MCSP Master Registry Data as of September 2024
Medical Risk Level Number of Patients Percentage*
High 1 783 19.3%
High 2 752 18.5%
Medium 1,821 44.8%
Low 707 17.4%
Total 4,063 100%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from the
CCHCS Master Registry dated 9-3-24.
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: February 2024 – July 2024 Report Issued: October 2025
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According to staffing data the OIG obtained from California Correctional Health Care
Services (CCHCS), as identified in Table 3 below, MCSP had no vacant executive
leadership positions, two primary care provider vacancies, 1.2 nursing supervisor
vacancies, and 43.7 nursing staff vacancies.
Table 3. MCSP Health Care Staffing Resources as of September 2024
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 6.0 18.0 22.7 226.7 273.4
Filled by Civil Service 6.0 16.0 21.5 184.0 227.5
Vacant 0 2.0 1.2 43.7 46.9
Percentage Filled by Civil Service 100.0% 88.9% 94.7% 81.2% 83.2%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0 0 0 0 0
Filled by Registry 0 0 0 33.0 33.0
Percentage Filled by Registry 0 0 0 14.6% 12.1%
Total Filled Positions 6.0 16.0 21.5 217.0 260.5
Total Percentage Filled 100.0% 88.9% 94.7% 95.7% 95.3%
Appointments in Last 12 Months 0 1.0 6.0 51.3 58.3
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 2.0 4.0 6.0
Adjusted Total: Filled Positions 6.0 16.0 19.5 213.0 254.5
Adjusted Total: Percentage Filled 100.0% 88.9% 85.9% 94.0% 93.1%
* 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 9-3-24, from California Correctional
Health Care Services.
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Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted above, the OIG
presents selected measures from the Healthcare Effectiveness Data and Information Set
(HEDIS) for comparison purposes. The HEDIS is a set of standardized quantitative
performance measures designed by the National Committee for Quality Assurance to
ensure that the public has the data it needs to compare the performance of health care
plans. Because the Veterans Administration no longer publishes its individual HEDIS
scores, we removed them from our comparison for Cycle 7. Likewise, Kaiser (commercial
plan) no longer publishes HEDIS scores. However, through the California Department of
Health Care Services’ Medi‑Cal Managed Care Technical Report, the OIG obtained
California Medi-Cal and Kaiser Medi-Cal HEDIS scores to use in conducting our
analysis, and we present them here for comparison.
HEDIS Results
We considered MCSP’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 colorectal cancer
screening rates for patients ages 45 to 75. For both poor HbA1C control and colorectal
cancer screening, MCSP’s results compared favorably with those found in State health
plans for this measure. 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)—MCSP’s
percentage of patients with poor HbA1c control was significantly lower, indicating very
good performance on this measure.
Immunizations
Statewide comparative data were not available for immunization measures; however, we
include these data for informational purposes. MCSP had a 44 percent influenza
immunization rate for adults 18 to 64 years old and an 80 percent influenza immunization
rate for adults 65 years of age and older.9 The pneumococcal vaccination rate was
95 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)—MCSP’s
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.
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colorectal cancer screening rate of 88 percent was significantly higher, indicating very
good performance on this measure.
Table 4. MCSP Results Compared with State HEDIS Scores
MCSP 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%) ‡,§ 7% 33% 26% 19%
HbA1c Control (< 8.0%) ‡ 84% – – –
Blood Pressure Control (< 140/90) ‡ 97% – – –
Eye Examinations 68% – – –
Influenza – Adults (18 – 64) 44% – – –
Influenza – Adults (65 +) 80% – – –
Pneumococcal – Adults (65 +) 95% – – –
Colorectal Cancer Screening 88% 40% 71% 71%
Notes and Sources
* Unless otherwise stated, data were collected in September 2024 by reviewing medical records from a
sample of MCSP’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 Medi-Cal
Managed Care Physical Health 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 MCSP 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: February 2024 – July 2024 Report Issued: October 2025
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Recommendations
As a result of our assessment of MCSP’s performance, we offer the following
recommendations to the department:
Diagnostic Services
• Medical leadership should determine the root cause(s) of challenges to
notifying patients of pathology test results and should implement remedial
measures as appropriate.
• The department should develop strategies, such as an electronic solution, to
ensure providers create patient notification letters when they endorse test
results and ensure patient notification letters contain all elements required
by CCHCS policy. The department should implement remedial measures as
appropriate.
Emergency Services
• The institution leadership should identify the challenges with staff not
immediately activating emergency medical services for emergent patients
requiring a higher level of care transfer, staff not prioritizing the automated
external defibrillator (AED) placement for patients who require CPR, and
custody transport teams arriving significantly after the ambulance arrives to
the institution. Leadership 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 EMRBs are regularly inventoried and sealed and should implement
remedial measures as appropriate.
Transfers
• Nursing leadership should identify strategies to ensure nursing staff
document pending specialty referrals for patients transferring to other
institutions in the EHRS, as per the Health Care Department Operations
Manual (HCDOM), and should implement remedial measures as appropriate.
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Medication Management
• Medical and nursing leadership should develop strategies to ensure chronic
care, hospital discharge, and en route patients receive their medications
timely and without interruption. Leadership should implement remedial
measures as appropriate.
• Nursing leadership should develop strategies to ensure nursing staff
document patient medication refusals in medication administration records,
as described in CCHCS policy and procedures, and should implement
remedial measures as appropriate.
Preventive Services
• Health care leadership should determine the root cause(s) for challenges to
timely providing immunizations to chronic care patients and should
implement appropriate remedial measures.
Nursing Performance
• Nursing leadership should determine the challenges to ensuring nurses
perform appropriate triage of sick call requests, complete and thorough face-
to-face assessments, and co-consults with providers when needed. Nursing
leadership should implement remedial measures as appropriate.
Provider Performance
• Medical leadership should determine the root cause(s) of challenges with
thorough provider assessments and review of medical records and should
implement remedial measures as appropriate.
Specialty Services
• Health care leadership should determine the root cause(s) of challenges to the
timely provision of preapproved specialty appointments for transfer patients
and should implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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Indicators
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing
patients with timely clinical appointments. Our inspectors reviewed scheduling and
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
specialists. Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (89.7%)
In this cycle, case review found MCSP provided very good access to care, on par with
Cycle 6. The institution delivered excellent access to providers and nurses. However, we
found two significant specialty appointment deficiencies, which delayed care.
Considering all factors, the OIG rated the case review component of this indicator
adequate.
Compliance testing showed MCSP performed very well in this indicator. Providers
performed excellently in timely evaluating newly transferred patients and in timely
completing provider follow-up appointments for patients returning from specialty
services. Staff performed fair to very well in assessing patients with chronic care
conditions and patients returning from hospitalizations within required time frames.
Nurses always reviewed all patient sick call requests timely and frequently completed
face-to-face triages as required. 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
The OIG clinicians reviewed 223 provider, nursing, specialty, and off-site hospital events
requiring a follow-up appointment. We identified four deficiencies related to access to
care. Three pertained to timely specialty services completion, two of which were
significant.11
Access to Care Providers
MCSP performed very well with provider access for patients. Compliance testing showed
very good access to chronic care follow-up appointments (MIT 1.001, 88.0%) and good
access to nurse-to-provider sick call referrals (MIT 1.005, 85.0%). Timely provision of
provider sick call follow-up appointments was excellent (MIT 1.006, 100%). Similarly, OIG
clinicians found no deficiencies in timely completing provider appointments.
11 Deficiencies occurred in cases 2, 16, and 23. Specialty service access deficiencies occurred in cases 2, 16, and
23. Significant specialty service access deficiencies occurred in cases 16 and 23.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
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Access to Clinic Nurses
MCSP performed excellently in nurse access for patients. Compliance testing showed
registered nurses always reviewed patients’ requests for service the same day they were
received (MIT 1.003, 100%). Similarly, registered nurses almost always completed face-to-
face appointments within one business day following sick call request reviews (MIT
1.004, 91.4%). OIG clinicians reviewed 58 nursing sick call requests and identified only
one minor deficiency related to clinic nurse access.12
Access to Specialty Services
The institution performed variably in timely completing specialty service appointments.
Compliance testing showed sufficient completion rates of high-priority (MIT 14.001,
80.0%) and routine-priority (MIT 14.007, 80.0%) appointments, along with a very good
completion rate of medium-priority (MIT 14.004, 86.7%) appointments. Testing further
showed completing high-priority follow-up appointments with specialists needed
improvement (MIT 14.003, 71.4%), but completing routine-priority follow-up
appointments was very good (MIT 14.009, 87.5%), and completing medium-priority
follow-up appointments was excellent (MIT 14.006, 100%). OIG clinicians found most
specialty appointments occurred within requested time frames but identified two
deficiencies, both of which were significant.13 The following is an example:
• In case 16, the provider ordered a cardiology specialty appointment.
However, the appointment occurred more than four weeks late.
We discuss this further in the Specialty Services indicator.
Follow-Up After Specialty Services
Compliance testing showed provider appointments after specialty services always
occurred within required time frames (MIT 1.008, 100%). Similarly, OIG clinicians
identified no deficiencies in timely provider appointments following specialty services.
Follow-Up After Hospitalization
MCSP’s management of post-hospitalization follow-up appointments with the provider
varied. Although compliance testing showed providers generally evaluated patients
timely after hospitalization (MIT 1.007, 76.0%), OIG clinicians found excellent follow-up
appointment completion with no deficiencies.
Follow-Up After Urgent or Emergent Care (TTA)
MCSP providers always evaluated their patients following a triage and treatment area
(TTA) event as medically indicated. OIG clinicians reviewed 19 TTA events and identified
no delays in provider follow-up appointments.
12 A minor deficiency related to clinic nurse access occurred in case 23.
13 Significant deficiencies occurred in cases 16 and 23.
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Follow-Up After Transferring Into MCSP
Access to care for patients who had recently transferred into the institution was mixed.
Compliance testing showed excellent access to intake appointments for newly arrived
patients (MIT 1.002, 100%). In contrast, compliance testing showed completion of pre-
approved specialty service appointments following transfer was poor (MIT 14.010, 45.0%).
OIG clinicians found no deficiencies in the three cases reviewed for intake appointment
access. We identified one minor deficiency with timely specialty service completion for a
transfer patient.14 We discuss this further in the Transfers indicator.
Clinician On-Site Inspection
OIG clinicians spoke with MCSP’s scheduling supervisor regarding the institution’s
access to care. MCSP had five main clinics: A, B, C, D, and E, each staffed with one to
three providers. Clinics A, B, and C were in the main MCSP complex. Clinics D and E
were located in the MCSP “Infill Complex,” situated away from the main complex. In
addition to its main clinics, the institution operated a restricted housing clinic, a
minimum-security facility clinic, a TTA, a correctional treatment center (CTC), and
specialty clinics. The specialty clinics offered audiology, orthotics, echocardiograms, GI
procedures (EGD and Colonoscopy), sleep studies, ultrasound, FibroScan, virtual speech
therapy, and virtual pulmonary rehabilitation.15
The OIG clinicians observed morning huddles, which were well attended by the patient
care team and staff. At the time of the on-site inspection, the scheduling supervisor
reported a backlog of 342 appointments concentrated in Clinic A. Multiple staff members
reported providing only urgent and emergent services in Clinic A within the two weeks
preceding the on-site inspection, triggering the backlog. They cited a rise in patient
violence as the reason for this adjustment.
Compliance On-Site Inspection and Discussion
Four of six housing units randomly tested at the time of inspection had access to health
care services request forms (CDCR Form 7362) (MIT 1.101, 66.7%). In two housing units,
custody officers did not have a system in place for restocking the forms. The custody
officers reported reliance on medical staff to replenish the forms in the housing units.
14 A minor deficiency occurred in case 2.
15 An echocardiogram is a procedure using an ultrasound to examine and image the heart. An EGD is an
esophagogastroduodenoscopy. In this procedure, the specialist uses a camera to examine the esophagus and the
stomach. A FibroScan is a diagnostic imaging used to evaluate for liver scarring and fatty changes from liver
disease.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 16
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 22 3 0 88.0%
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 25 0 0 100%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
35 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
32 3 0 91.4%
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
17 3 15 85.0%
maximum allowable time or the ordered time frame, whichever is the
shorter? (1.005)
Sick call follow-up appointments: If the primary care provider ordered a
follow-up sick call appointment, did it take place within the time frame 1 0 34 100%
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
19 6 0 76.0%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
31 0 14 100%
occur within required time frames? (1.008) *
Clinical appointments: Do patients have a standardized process to obtain
4 2 0 66.7%
and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 89.7%
* 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: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 17
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
N/A N/A N/A N/A
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 12 3 0 80.0%
Request for Service? (14.001)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 5 2 8 71.4%
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 13 2 0 86.7%
for Service? (14.004)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 8 0 7 100%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 12 3 0 80.0%
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: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 18
Recommendations
The OIG offers no recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 19
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 Inadequate (70.6%)
Similar to Cycle 6, case review found MCSP performed satisfactorily with diagnostic
services in Cycle 7. Staff provided excellent access to diagnostic services, and providers
almost always endorsed test results timely. However, we also found patterns of missing or
incomplete patient test result notification letters. After considering all aspects, the OIG
rated the case review component of this indicator adequate.
Compliance testing showed MCSP performed variably for this indicator. Staff always
completed and endorsed radiology as well as laboratory tests timely. They usually
reviewed and endorsed pathology results within specified time frames. However, staff
needed improvement in retrieving pathology reports and in generating complete patient
test result notification letters with all required elements. Based on the overall Diagnostic
Services compliance score result, the OIG rated the compliance testing component of this
indicator inadequate.
Case Review and Compliance Testing Results
The OIG clinicians reviewed 216 diagnostic-related events and identified 41
deficiencies.16 None of the deficiencies were significant, and all related to health
information management.
Test Completion
MCSP performed perfectly in diagnostic service completion for both compliance testing
and case review. Compliance testing revealed staff always completed radiology services
(MIT 2.001, 100%) and laboratory services (MIT 2.004, 100%) within required time frames.
OIG clinicians similarly identified no deficiencies in timely providing diagnostic
services.
Neither case review nor compliance testing had any STAT laboratory tests to review in
their samples (MIT 2.007, N/A).
16 Deficiencies occurred in cases 10, 12–18, 21–23, 27, 29, and 30.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 20
Health Information Management
As with test completion, MCSP performed excellently in diagnostic test endorsement.
Compliance testing showed providers always endorsed radiology (MIT 2.002, 100%) and
laboratory (MIT 2.005, 100%) results timely. Similarly, OIG clinicians found providers
almost always endorsed radiology and laboratory results timely. We identified only two
minor deficiencies related to providers untimely endorsing laboratory results.17
In contrast, providers needed improvement with timely notifying patients of diagnostic
test results with complete letters. Compliance testing revealed MCSP’s patient
notification letters of laboratory results needed improvement (MIT 2.006, 60.0%), while
notification letters of radiology results was poor (MIT 2.003, 30.0%). OIG clinicians also
identified 39 minor deficiencies related to sending incomplete patient test result
notification letters or not sending patient test result notification letters at all.18
MCSP performed variably in managing pathology reports. Compliance testing showed
staff intermittently received the final pathology reports timely (MIT 2.010, 70.0%), and
providers generally reviewed and endorsed pathology reports (MIT 2.011, 75.0%) within
required time frames. In contrast, compliance testing revealed providers never
communicated the results of pathology studies with complete patient notification letters
within specified time frames (MIT 2.012, zero). OIG clinicians also identified two minor
deficiencies related to patient notification letters for pathology results.19
We also discuss this in the Health Information Management indicator.
Clinician On-Site Inspection
OIG clinicians met with MCSP’s correctional health services administrator II (CHSA II)
and providers to discuss diagnostic procedures. The CHSA II reported having staff
shortages only for radiology services during the review period and at the time of the on-
site inspection. A retired annuitant had been assisting in the senior radiology technician
position by working four-hour shifts, three days per week. When asked about current
backlogs, the CHSA II reported no current radiology backlog. However, the CHSA II
reported, due to a recent increase of violence in A Yard, laboratory services was only able
to complete urgent and emergent tests, resulting in a small backlog.
Generally, providers reported no issues with obtaining timely laboratory and diagnostic
services. Most providers acknowledged having access to STAT laboratory tests; however,
they usually opted to transfer patients to a higher level of care if the need for a STAT
laboratory test arose. All clinics had their own laboratory draw areas.
17 Two minor deficiencies occurred in case 21.
18 Minor deficiencies occurred in cases 10, 12–18, 22, 23, 27, 29, and 30.
19 Minor deficiencies occurred in cases 27 and 29.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 21
Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
10 0 0 100%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
3 7 0 30.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
10 0 0 100%
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
6 2 2 75.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 8 2 0
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 70.6%
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 22
Recommendations
• Medical leadership should determine the root cause(s) of challenges to
notifying patients of pathology test results and should implement remedial
measures as appropriate.
• The department should develop strategies, such as an electronic solution, to
ensure providers create patient notification letters when they endorse test
results and ensure patient notification letters contain all elements required
by CCHCS policy. The department should implement remedial measures as
appropriate.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 23
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
Inadequate Not Applicable
In this cycle, case review found MCSP’s overall performance needed improvement in
emergency services. Compared with Cycle 6, we identified an increase in the number of
significant deficiencies this cycle. The providers performed excellent care. We found
nurses generally completed good assessments and documented appropriately. In
addition, medical leadership performed well with completing clinical reviews and
identifying training opportunities. However, we found health care staff needed
improvement in timely notifying emergency medical services (EMS) and prioritizing
automated external defibrillator (AED) placement for patients who required CPR, and
custody staff needed improvement in timely transporting patients to a higher level of care
by.20 Factoring all the information, the OIG rated this indicator inadequate.
Case Review Results
We reviewed 40 urgent and emergent events and found 24 emergency care deficiencies.
Of these 24 deficiencies, nine were significant.21
Emergency Medical Response
OIG clinicians found MCSP needed improvement in medical emergency response.
Custody and medical staff often initiated CPR without delay and administered naloxone
appropriately for patients with a suspected drug overdose.22 Nurses generally performed
good assessments and documented appropriately for urgent and emergent events.
20 An automated external defibrillator (AED) is a portable device used to deliver an electric shock to the heart
when it detects an abnormal heart rhythm.
21 Deficiencies occurred in cases 2–6, 10, 11, and 23–26. Significant deficiencies occurred in cases 2–6, 23, and
25.
22 Naloxone is a medication used for the emergency treatment of known or suspected opioid overdose.
According to the manufacturer, nasal naloxone doses can be safely administered every two to three minutes.
CCHCS emergency medical training allows nurses to administer up to five nasal naloxone doses when an opioid
overdose is suspected.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 24
However, OIG clinicians identified multiple concerning delays in notifying EMS,
applying the AED, and custody arrival after EMS for patient transport. The following are
examples.
• In case 3, staff activated an emergency medical alarm for this patient with
complaints of chest pain. Nurses provided emergency care and received
orders to transport the patient to a higher level of care. EMS arrived at
10:58 a.m. However, the custody transport team did not arrive to the patient
until 11:11 a.m., 13 minutes later, which delayed transporting the patient to
the hospital.
• In case 4, at 3:55 p.m., custody staff activated a medical emergency alarm for
this patient, who was found unresponsive in his cell. Three minutes later,
health care staff arrived to find the patient not breathing, with no pulse, and
initiated CPR. After two rounds of CPR, the patient had a return of
spontaneous circulation and was transferred to a higher level of care.23
However, the nurses did not apply the AED on the patient when they found
him with no pulse or respirations.
• In case 5, custody staff activated an emergency medical alarm and initiated
CPR for this patient with a suspected drug overdose. However, staff did not
contact EMS until five minutes after activating the emergency medical alarm.
Similar deficiencies occurred in cases 2, 4, and 6.
• In case 6, at 5:37 p.m., nursing staff responded to a medical emergency alarm
for this patient, who was found hanging in his cell. Upon arrival, nursing
staff found custody staff providing CPR for the patient. Nursing staff
assessed the patient and provided life-saving interventions; however, they did
not apply the AED until 5:42 p.m., four minutes later.
• In case 26, custody staff activated an emergency medical alarm for this
patient with stroke symptoms. Staff immediately initiated EMS, and the
ambulance arrived to the patient at 7:42 a.m. However, the custody transport
team did not arrive until 7:59 a.m., 17 minutes later, delaying patient
transport to the hospital.
Provider Performance
MCSP providers appropriately managed patients in the TTA with urgent or emergent
conditions. OIG clinicians identified no emergency provider care deficiencies.
Emergency Medical Response Review Committee
OIG clinicians reviewed 21 emergency events in which patients transferred to a higher
level of care, including patient deaths.24 We found medical leadership overall performed
well with conducting clinical reviews and identifying opportunities for improvement.
However, compliance testing revealed the emergency medical response and unscheduled
23 Return of spontaneous circulation is the resumption of a sustained heart rhythm that perfuses the body after
cardiac arrest. Clinically, the health care provider will check and identify a central pulse.
24 Emergency events requiring emergency transport to a higher level of care occurred in cases 1–11, 17, and 23–
26.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 25
transport event checklists were often incomplete or not completed at all (MIT 15.003,
66.7%).
Clinician On-Site Inspection
OIG clinicians toured the TTA located in the MCSP main facility. Two registered nurses
(RNs) were staffed in the TTA each shift, with one provider assigned Monday through
Friday from 7:00 a.m. to 5:00 p.m., and an on-call provider covering after hours. The TTA
consisted of four rooms, including one designated for casting or splinting and another for
patient observation. We interviewed the day shift nurses, who explained they responded
to all medical emergency alarms alongside the licensed vocational nurses (LVNs) from
the designated yards. They indicated a high volume of medical emergency alarms,
reporting approximately 36 alarms in a single shift. According to the staff, this increase
was due to an influx of patients with multiple medical complexities, who recently
transferred in from various facilities.
We also toured the TTA in the MCSP “Infill Complex” and interviewed the day shift
nursing staff. Two RNs staffed each shift, and one provider covered the day shift Monday
through Friday. If the provider was unavailable, the nurses would contact the patient’s
primary care provider for emergency care. Staff reported handling an average of one
emergency event per day and saw an average of one to two walk-in patients per day. Staff
indicated the patient care team did a great job of managing the patient care population.
Nursing leadership shared the primary care nurses did not respond to medical emergency
alarms unless additional help was needed. They planned to implement a pilot program in
the near future that would require the clinic nurses to respond to medical emergency
alarms.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 26
Recommendations
• The institution leadership should identify the challenges with staff not
immediately activating emergency medical services for emergent patients
requiring a higher level of care transfer, staff not prioritizing the automated
external defibrillator (AED) placement for patients who require CPR, and
custody transport teams arriving significantly after the ambulance arrives to
the institution. Leadership should implement remedial measures as
appropriate.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 27
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 (92.0%)
Case review found MCSP performed satisfactorily in this indicator. Staff performed
excellently with timely retrieving and processing medical records, and providers almost
always timely reviewed diagnostic test results. However, we identified two deficiency
patterns: an on-site specialist routinely did not forward consultation reports to the
providers for review, and providers often sent incomplete patient test result notification
letters or never sent the letters at all. These deficiencies were not clinically significant.
Considering all factors, the OIG rated the case review component of this indicator
adequate.
Compliance testing showed MCSP performed very well in this indicator. Staff always
scanned patient sick call requests and reviewed hospital discharge reports timely. Staff
performed very well in scanning specialty and hospital discharge reports, and staff
sufficiently labeled medical records and filed them in the appropriate patient files. Based
on the overall Health Information Management compliance score result, the OIG rated
the compliance component of this indicator proficient.
Case Review and Compliance Testing Results
The OIG clinicians reviewed 945 events and identified 60 deficiencies related to health
information management, only one of which was significant.25
Hospital Discharge Reports
MCSP staff performed well in hospital records management. Staff timely retrieved and
scanned hospital discharge records into the electronic health records system (EHRS)
within required time frames (MIT 4.003, 90.0%).26 OIG clinicians reviewed 17 off-site
25 Deficiencies occurred in cases 1, 3, 9, 10, 12–18, 20–23, 25–27, 29, and 30. A significant deficiency occurred in
case 22.
26 EHRS is the Electronic Health Records System. The department’s electronic health record system is used for
storing the patient’s medical history and health care staff communication.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 28
emergency department and hospital encounters and identified no deficiencies with
MCSP staff’s management of hospital discharge reports.
Specialty Reports
Compliance testing showed MCSP performed satisfactorily in managing specialty
reports. Staff often scanned specialty reports timely. (MIT 4.002, 86.7%) Providers
frequently endorsed routine-priority (MIT 14.008, 80.0%), medium-priority (MIT 14.005,
85.7%), and high-priority (MIT 14.002, 85.7%) specialty reports within required time
frames.
OIG clinicians identified 16 deficiencies related to specialty report management.27 Of
those 16 deficiencies, 13 pertained to an on-site specialist not forwarding reports to
providers for endorsement.28 The remaining three deficiencies related to late scanning,
late provider endorsement, and health information management (HIM) staff not
forwarding specialty reports.29 This last HIM staff deficiency was significant.
We also discuss these findings in the Specialty Services indicator.
Diagnostic Reports
Providers performed very well in endorsing laboratory and radiology results within
specified time frames. Compliance testing showed providers always endorsed radiology
(MIT 2.002, 100%) and laboratory (MIT 2.005, 100%) results timely. Similarly, OIG
clinicians found providers almost always endorsed radiology and laboratory results
timely. OIG clinicians identified only two minor deficiencies related to untimely provider
endorsement of laboratory results.30
Neither case review nor compliance testing had any STAT laboratory tests to review in
their samples (MIT 2.007, N/A).
MCSP showed mixed performance in managing pathology results. Compliance testing
revealed staff sometimes received final pathology reports (MIT 2.010, 70.0%), and
providers usually reviewed and endorsed pathology reports (MIT 2.011, 75.0%) within
required time frames. However, providers never communicated the results of pathology
studies with patient notification letters within specified time frames (MIT 2.012, zero).
OIG clinicians identified two minor deficiencies related to patient notification letters of
pathology test results.31
Providers similarly struggled with timely patient notification with complete letters of
other diagnostic test results. OIG clinicians identified 39 minor deficiencies related to
missing or incomplete patient test result notification letters.32
27 Deficiencies occurred in cases 1, 3, 9, 12, 15–18, 20–22, 25, 26, and 29.
28 Deficiencies in which the on-site specialist did not forward the report to the provider for endorsement
occurred in cases 1, 3, 9, 15–18, 20, 21, 25, 26, and 29.
29 Two deficiencies, one in late scanning and one in provider endorsement, each occurred in case 12. A
significant HIM deficiency related to not forwarding the specialty report to the provider occurred in case 22.
30 Two minor deficiencies occurred in case 21.
31 Minor deficiencies occurred in cases 27 and 29.
32 Minor deficiencies occurred in cases 10, 12–18, 22, 23, 27, 29, and 30.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 29
We also discuss patient notification letters in the Diagnostic Services indicator.
Urgent and Emergent Records
OIG clinicians reviewed 41 emergency care events and found MCSP nurses and providers
documented these events satisfactorily. The providers also sufficiently recorded their
emergency care, including off-site telephone encounters. We identified no deficiencies.
Refer to the Emergency Services indicator for additional discussion on emergency care
documentation.
Scanning Performance
Compliance testing showed MCSP performed acceptably with scanning, labeling, and
filing (MIT 4.004, 83.3%). OIG clinicians also identified only two minor deficiencies.33
Clinician On-Site Inspection
OIG clinicians discussed health information management processes with MCSP’s health
records technician (HRT) supervisor and correctional health services administrator
(CHSA). HIM management described the process for retrieving off-site specialty reports.
One of the HIM department’s main responsibilities was obtaining off-site specialty
service reports within 48 hours of the specialty service appointments. Upon receiving
these records, the HRT would then scan the records into EHRS and forward them to the
primary care provider for review and signature. The HIM supervisors reported challenges
to obtaining one local dermatology specialist’s reports timely.
To track provider report endorsements, the HIM supervisors reported completing a
monthly audit. They would send the results of their audit in a deficiency report to the
provide, and they provided copies to the chief medical executive (CME) and each chief
physician and surgeon (CP&S).
Regarding staffing, the HIM supervisors reported during the review period having one
vacancy for an HRT and one vacancy for an office assistant (OA). They cited the budget as
a barrier to filling these positions.
33 Two minor deficiencies occurred in case 3.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 30
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 15 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
26 4 15 86.7%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 18 2 5 90.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
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 25 0 0 100%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 92.0%
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 31
Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
10 0 0 100%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
10 0 0 100%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
7 3 0 70.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
6 2 2 75.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 8 2 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 12 2 1 85.7%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 12 2 1 85.7%
frame? (14.005)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 12 3 0 80.0%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 32
Recommendations
The OIG offers no recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 33
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 (60.7%)
Overall, MCSP’s performance with health care environment needed improvement.
Medical supply storage areas contained expired, unorganized, unidentified, or
inaccurately labeled medical supplies. In addition, several clinics did not meet the
requirements for essential core medical equipment and supplies. Moreover, staff did not
regularly sanitize or wash their hands during patient encounters. Lastly, emergency
medical response bags (EMRB) logs were missing staff verification or contained
compromised medical supply
packaging, and staff did not
perform inventory when replacing
seal tags. Based on the overall
Health Care Environment
compliance score result, the OIG
rated this indicator inadequate.
Compliance Testing
Results
Patient Waiting Areas
We inspected only indoor waiting
areas as MCSP had no outdoor
waiting areas. Health care and
custody staff reported existing
waiting areas contained sufficient
seating capacity (see Photo 1).
During our inspection, we did not
observe overcrowding in any of
the clinics’ indoor waiting areas. Photo 1. Indoor patient waiting area
(photographed on 9-24-24).
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Clinic Environment
Eleven of 13 applicable 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, 84.6%). In two clinics, we
observed patients being seen at the same time for vital sign checks and blood draws at
the triage stations, which hindered auditory privacy (see Photo 2, below).
Photo 2. Vital signs and blood draw stations were located next to each other
(photographed on 9-23-24).
Ten of the 13 applicable clinics we observed contained appropriate space, configuration,
supplies, and equipment to allow their clinicians to perform proper clinical examinations
(MIT 5.110, 76.9%). In two clinics, we observed staff left the computer screens unlocked
displaying confidential medical records, leaving them accessible to unauthorized persons.
In one clinic, staff did not shred confidential medical records daily.
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Clinic Supplies
Staff in five of the 13 applicable clinics followed adequate medical supply storage
and management protocols (MIT 5.107, 38.5%). We found one or more of the
following deficiencies in eight clinics: unorganized, unidentified, or inaccurately
labeled medical supplies; medical supplies stored with staff’s personal items,
disinfectants, or medications (see Photo 3, below); long-term storage of staff’s food
in the medical supply storage room (see Photo 4, next page); and expired medical
supplies (see Photo 5, next page).
Photo 3. Medical supply stored with
medications (photographed on 9-23-24).
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Photo 4. Long-term storage of staff
members’ food in the medical supply
storage room (photographed on 9-23-24).
Photo 5. Expired medical supply dated
August 2024 (photographed on 9-23-24).
Seven of the 13 applicable clinics met the requirements for essential core medical
equipment and supplies (MIT 5.108, 53.9%). In five clinics, MCSP staff inconsistently
documented the AED performance test results within the last 30 days. In one additional
clinic, one peak flow meter and associated disposable tips were missing, and staff had not
completed the defibrillator performance test log documentations within the last 30 days.
We examined EMRBs to determine whether they contained all essential items. We
checked whether staff inspected the bags daily and inventoried them monthly. Four of
the 10 EMRBs passed our test (MIT 5.111, 40.0%). We found one or more of the following
deficiencies in six locations: staff did not ensure the EMRB’s compartments were sealed
and intact; staff had not inventoried the EMRBs when the seal tags were replaced;
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EMRBs contained medical supplies with compromised packaging; and staff inaccurately
logged the EMRB daily glucometer quality control results.
Medical Supply Management
None of the medical supply storage areas located outside the medical clinics stored
medical supplies appropriately (MIT 5.106, zero). We found medical supplies stored
beyond the range of manufacturers’ temperature guidance (see Photos 6 and 7, below).
Photo 7. Medical supply’s manufacturer required
storage temperature set between 59°F and 77°F
(photographed on 9-23-24).
Photo 6. Medical supply stored beyond
manufacturer’s temperature guidelines
(photographed on 9-23-24).
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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 13 applicable clinics (MIT
5.101, 53.9%). In six clinics, we found one or both of the following deficiencies: cleaning
logs were not maintained or the health care area had insects (see Photos 8 and 9, below).
Photo 9. Insect in the health care area
(photographed on 9-24-24).
Photo 8. Insect in the health care area
(photographed on 9-24-24).
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Staff in all clinics properly sterilized or disinfected medical equipment (MIT 5.102, 100%).
We found operational sinks and hand hygiene supplies in the examination rooms in 10 of
13 applicable clinics (MIT 5.103, 76.9%). The patient restrooms in three clinics lacked
antiseptic soap.
We observed patient encounters in seven applicable clinics. In four clinics, clinicians did
not wash their hands before examining their patients, before applying gloves, before
performing blood draws, or before and after performing wound care (MIT 5.104, 42.9%).
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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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 6 1 53.9%
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 13 0 1 100%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
10 3 1 76.9%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
3 4 7 42.9%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
13 0 1 100%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 0 1 0 0
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
5 8 1 38.5%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
7 6 1 53.9%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
11 2 1 84.6%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
10 3 1 76.9%
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 4 6 4 40.0%
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): 60.7%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Mule Creek 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 EMRBs are regularly inventoried and sealed and should implement
remedial measures as appropriate.
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Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions.
For newly arrived patients, our inspectors assessed the quality of health care screenings
and the continuity of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, inspectors checked
whether staff reviewed patient medical records and determined the patient’s need for
medical holds. They also assessed whether staff transferred patients with their medical
equipment and gave correct medications before patients left. In addition, our inspectors
evaluated 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 Adequate (78.0%)
Case review found MCSP performed sufficiently in the transfer process, similar to
Cycle 6. Nurses performed good assessments for new patients arriving to the institution
and for patients returning from the hospital. Staff scheduled nurse and provider
appointments timely for newly arrived patients. For patients transferring out of MCSP,
nurses ensured all essential medications and required documents were included in
transfer packets. However, we identified opportunities for improvement in nursing
documentation of pending specialty referrals when patients transferred to another
institution. Considering all factors, the OIG rated the case review component of this
indicator adequate.
Compared with Cycle 6, MCSP’s overall performance improved for this indicator. MCSP
needed improvement in completing initial health screening forms and ensuring
medication continuity for newly transferred patients. However, the institution performed
excellently in completing assessment and disposition sections of the screening process
and ensuring transfer packets for departing patients included required documents and
medications. Based on the overall Transfers compliance score result, the OIG rated the
compliance testing component of this indicator adequate.
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Case Review and Compliance Testing Results
OIG clinicians reviewed 43 events in 18 cases in which patients transferred into or out of
the institution or returned from an off-site hospital or emergency room. We identified 11
deficiencies, three of which were significant.34
Transfers In
OIG clinicians reviewed 11 events in which patients transferred into the facility from
35
other institutions. We identified two deficiencies, neither of which was significant.
OIG clinicians found nurses performed very well in completing the healthcare screening
form thoroughly and scheduling nurse and provider follow-up appointments timely.
Compliance testing revealed nurses needed improvement in completing the initial health
screening form timely and providing an explanation for questions answered “yes” on the
screening form (MIT 6.001, 72.0%). However, compliance testing showed nurses always
completed the assessment and disposition section of the healthcare screening form (MIT
6.002, 100%).
Compliance testing showed nurses needed improvement needed with medication
continuity for patients who transferred into the facility (MIT 6.003, 40.0%). The low score
was mostly due to nurses not documenting identified barriers or the reason for patient
refusals on the medication administration record (MAR). Compliance testing also showed
staff only occasionally maintained medication continuity without interruption for
patients who transferred from one housing unit to the another (MIT 7.005, 48.0%). In
addition, compliance testing revealed MCSP performed poorly with ensuring patients
laying over at the facility received their medications without interruption (MIT 7.006,
30.0%). The low score was mainly due to not documenting medication delivery by the next
dosing interval. In contrast, OIG clinicians found staff administered medications in their
cases without a disruption in medication continuity.
Compliance testing showed MCSP performed excellently with ensuring a provider
evaluated new patient arrivals within required time frames (MIT 1.002, 100%). However,
compliance testing revealed MCSP performed poorly with scheduling preapproved
specialty appointments within required time frames (MIT 14.010, 45.0%). Case review
only identified one deficiency with a pending specialty appointment that was not
reconciled when the patient arrived at the institution, meaning the appointment was not
scheduled.36
Transfers Out
Compliance testing showed MCSP performed excellently in including the required
medications and corresponding transfer documents in transfer packets (MIT 6.101, 100%).
While case review found nurses generally completed transfer information and
administered medications prior to transfer, in three cases we identified a pattern of
34 Deficiencies occurred in cases 2, 3, 10, 23, 26, 34, and 35. Significant deficiencies occurred in cases 23 and 26.
35 Transfer-in deficiencies occurred in cases 2 and 10.
36 A specialty service appointment deficiency occurred in case 2.
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nurses not documenting pending specialty referrals and appointments.37 The following is
an example:
• In case 36, the nurse completed the preboarding transfer screening form for
this patient, who was transferring out to another institution. However, the
nurse did not document in EHRS the patient’s pending specialty referrals for
the ear, nose, and throat specialist, the allergy specialist, or the follow-up
appointment with gastroenterology specialist.38
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.
The OIG compliance team found MCSP performed satisfactorily in ensuring patients had
timely follow-up appointments after hospitalizations or emergency room encounters
(MIT 1.007, 76.0%) and performed well in retrieving and scanning hospital records (MIT
4.003, 90.0%). In addition, providers always reviewed hospital discharge documents within
required time frames (MIT 4.005, 100%). OIG clinicians reviewed 13 events in which
patients returned from a hospitalization or emergency room, and we found nurses
performed excellently in completing thorough assessments and communicating hospital
recommendations to the provider upon these patients’ returns.
Compliance testing revealed MCSP performed poorly with administering medications
without interruption for patients who returned from a hospitalization or emergency room
encounter (MIT 7.003, 8.0%). The low score was mostly due to staff not making
medications available or administering them to patients by the provider-ordered date or
time. These medications included those to treat infections, high blood pressure, high
cholesterol, thyroid conditions, and glaucoma.39
OIG clinicians identified three significant deficiencies related to medication continuity
for patients returning after hospitalization.40 Please see the Medication Management
indicator for further discussion.
Clinician On-Site Inspection
OIG clinicians toured both receiving and release (R&R) locations in the MCSP main
facility and the MCSP “Infill Complex.” In each R&R location, the R&R was staffed with
one RN on the day shift and one on the evening shift, with the TTA RN covering the
night shift. We found staff knowledgeable about the transfer process. On average, the
37 Documentation deficiencies for specialty referrals and pending appointments occurred in cases 10, 35, and 36.
38 A gastroenterology specialist is a doctor who diagnosis and manages conditions of the digestive system,
including the esophagus, stomach, intestines, liver, pancreas, and gallbladder.
39 Glaucoma is a condition with increased eye pressure and can cause vision loss.
40 Hospital return medication deficiencies occurred in cases 23 and 26.
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Cycle 7, Mule Creek State Prison | 45
lower facility had 15 patients transferring into MCSP daily and five patients transferring
out daily, and the upper facility had five to 10 patient transfers in and out each week.
The R&R nurses were knowledgeable regarding the transfer process. The staff indicated
they printed a transfer bus list a week in advance, and nurses conducted a chart review to
check for any pending specialty appointments and referrals for those patients on the list.
They reported notifying the receiving institution about patients with pending specialty
referrals either by phone to provide a report or by sending a message via the message
pool in EHRS. In addition, the nurses documented pending specialty referrals or
appointments in EHRS prior to transfer. Furthermore, on the day of transfer, nurses
would review charts and print out any new orders to be included in transfer packets to
ensure continuity of care.
Compliance On-Site Inspection and Discussion
R&R nursing staff ensured all eight applicable patients transferring out of the institution
had their required medications, transfer documents, and assigned durable medical
equipment (MIT 6.101, 100%).
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Compliance Score Results
Table 11. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Did nursing
staff complete the initial health screening and answer all screening 18 7 0 72.0%
questions within the required time frame? (6.001)
For endorsed patients received from another CDCR institution: When
required, did the RN complete the assessment and disposition section of
the initial health screening form; refer the patient to the TTA if TB signs and 25 0 0 100%
symptoms were present; and sign and date the form on the same day staff
completed the health screening? (6.002)
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 6 9 10 40.0%
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 8 0 2 100%
required documents? (6.101)
Overall percentage (MIT 6): 78.0%
Source: The Office of the Inspector General medical inspection results.
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Table 12. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 25 0 0 100%
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 19 6 0 76.0%
required time frame? (1.007)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 18 2 5 90.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 25 0 0 100%
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 2 23 0 8.0%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
12 13 0 48.0%
medications continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 3 7 0 30.0%
administered or delivered without interruption? (7.006)
For endorsed patients received from another CDCR institution: If the
patient was approved for a specialty services appointment at the sending
9 11 0 45.0%
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
• Nursing leadership should identify strategies to ensure nursing staff
document pending specialty referrals for patients transferring to other
institutions in the EHRS, as per the Health Care Department Operations
Manual (HCDOM), and should implement remedial measures as appropriate.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in
administering prescription medications on time and without interruption. The inspectors
examined this process from the time a provider prescribed medication until the nurse
administered the medication to the patient. In addition to examining medication
administration, our compliance inspectors also tested many other processes, including
medication handling, storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (60.1%)
In this cycle, case review found MCSP’s overall performance sufficient in medication
management. We found the institution performed very well with ensuring patients
received their newly prescribed medications without any interruption and performed
excellently with medication administration for patients who transferred into and out of
the facility. However, we found MCSP continued to have challenges with medication
continuity for patients on chronic care medications and medications for patients
returning from the hospital. Considering all factors, the OIG rated the case review
component of this indicator adequate.
Compliance testing showed MCSP needed improvement in providing medication
management services. MCSP performed poorly in providing patients with chronic care
medications, community hospital discharge medications, and in ensuring medication
continuity for patients laying over at the facility. 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 152 events in 31 cases related to medications and found 23 medication
deficiencies, nine of which were significant.41
New Medication Prescriptions
OIG clinicians found MCSP performed very well with timely administering newly
prescribed medications. We identified two deficiencies in two cases in which the patients
received their newly prescribed medications one to two days late.42 In contrast,
compliance testing revealed newly prescribed medications were not always available or
administered by the provider-ordered date or time (MIT 7.002, 64.0%). Analysis of the
41 Deficiencies occurred in cases 1, 3, 9, 10, 15, 18, 21, 23–26, 29, and 30. Significant deficiencies occurred in
cases 3, 15, 21, 23, 24, 26, and 29.
42 New medication deficiencies occurred in cases 1 and 25.
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compliance data showed patients often received their newly prescribed medications late,
including medications to treat infections and high cholesterol.
Chronic Medication Continuity
Compliance testing revealed MCSP performed poorly with ensuring patients received
their chronic care medications within required time frames (MIT 7.001, 5.6%). The low
score was mostly due to the pharmacy not filling or dispensing medications timely. In
addition, nursing staff did not always document a reason when patients refused to take a
medication. Similarly, OIG clinicians found MCSP had many lapses in administering
chronic care medications. The following are examples:
• In case 3, during the month of March 2024, the patient was scheduled to
receive their keep-on-person (KOP) chronic care medication for heart
disease.43 However, the patient received the medication in April 2024, more
than one month later.
• In case 15, during the month of April 2024, the patient was due to receive
their KOP chronic care diabetic medication. However, the patient only
received a 15-day supply of the medication in April instead of the 30-day
supply for the month.
• In case 21, during the month of June 2024, the patient did not receive KOP
chronic care medication, tamsulosin.44 The patient received the medication
in July 2024, one month later.
Hospital Discharge Medications
Compliance testing showed MCSP performed poorly in medication continuity for
patients who were discharged from a community hospital (MIT 7.003, 8.0%). Analysis of
the compliance data showed the low score was mostly due to staff not making
medications available by the provider-ordered date and time. OIG clinicians identified
three significant deficiencies related to hospital discharge medications.45 The following is
an example:
• In case 23, the patient with a history of chronic obstructive pulmonary
disease returned from the hospital with a discharge diagnosis of pneumonia.
The nurse obtained a telephone order from the provider for the patient’s
medications; however, the order for the rescue inhaler was entered to begin
four days later, rather than the same day. Consequently, the patient did not
receive the KOP rescue inhaler prior to being discharged to the housing unit.
43 KOP means “keep on person” and refers to medications that a patient can keep and self-administer according
to the directions provided.
44 Tamsulosin is prescribed to treat symptoms from an enlarged prostate.
45 Hospital discharge medication deficiencies occurred in cases 23 and 26.
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Specialized Medical Housing Medications
Both case review and compliance testing did not have any applicable samples to review
for medication management during the review period.
Transfer Medications
Compliance testing showed MCSP performed excellently with ensuring all patients who
transferred out of the facility had a five-day supply of medications (MIT 6.101, 100%).
However, MCSP needed improvement with medication continuity for patients who
transferred into the institution (MIT 6.003, 40.0%). Compliance testing revealed nurses
did not always document identified barriers or the reason for patient refusals on the
MAR. Furthermore, compliance testing showed the institution only sporadically
maintained continuity for patients who transferred from one housing unit to another
(MIT 7.005, 48.0%). In addition, MCSP performed poorly with ensuring patient layovers
received their next medication dose at the appropriate interval (MIT 7.006, 30.0%).
In contrast, OIG clinicians found MCSP performance with transfer medications was
excellent. We did not identify any medication deficiencies for patients who transferred
into and out of the institution.
Medication Administration
Compliance testing showed MCSP performed very well with administering TB
medications and found nurses mostly monitored the patients taking TB medications as
required (MIT 9.002, 92.3%). OIG clinicians did not identify any concerns related to TB
medications.
Clinician On-Site Inspection
OIG clinicians toured the medication clinics on A Yard and E Yard and interviewed the
LVNs. Staff informed us A Yard and E Yard each had four medication nurses on the day
and evening shifts. The medication rooms were clean, spacious, and appeared well
organized. The nurses were knowledgeable about the medication administration process,
including processes for KOP medications as well as for patients who were non-compliant
with medication.
We found the A Yard medication nurses followed a structured process to ensure patients
received every opportunity to obtain their KOP medications within four days before
returning the medication to pharmacy. According to the nurses, they provided a
medication list to custody staff for posting in the buildings and on the medication line
window. If a patient did not pick up their medication on day two of the posting, the
nurses would schedule the patient to come to the clinic to either pick up their medication
or sign a refusal form. If a patient did not show for their scheduled appointment, the
nurses would go to the patient’s cell to have the patient complete a refusal form. The
medication nurses communicated any medication noncompliance issues to the providers,
and the patient care team discussed the issues in the daily huddle. In addition, they
scheduled any patients who were noncompliant with medications for a medication
counseling appointment with the clinic RNs.
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The LVNs stated their additional duties included administering vaccine injections,
completing preprocedural preparation forms, and performing medical first responder
assignments to all medical emergency alarms.
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in all 11 applicable
clinic and medication line locations (MIT 7.101, 100%).
MCSP appropriately stored and secured nonnarcotic medications in three of 12
applicable clinic and medication line locations (MIT 7.102, 25.0%). In nine locations, we
observed one or more of the following deficiencies: the medication storage area was
unclean; the medication area lacked a clearly labeled designated area for medications to
be returned to the pharmacy; medications were not securely stored as required by
CCHCS policy; nurses did not maintain unissued medications in the original labeled
packaging; and the treatment cart log was missing security check entries.
Staff kept medications protected from physical, chemical, and temperature
contamination in five of 12 applicable clinic and medication line locations (MIT 7.103,
41.7%). In seven locations, we found one or more of the following deficiencies: staff did
not consistently record the room temperature; staff stored medications with personal
items or disinfectants; the medication refrigerator was unsanitary; and staff did not store
several medications within the manufacturers’ temperature guidelines.
Staff successfully stored valid, unexpired medications in 11 of 12 applicable medication
line locations (MIT 7.104, 91.7%). In one location, medication nurses did not label the
multi-use medication as required by CCHCS policy, and staff did not store intravenous
(IV) solutions according to manufacturers’ guidelines.
Nurses exercised proper hand hygiene and contamination control protocols in three of
seven applicable locations (MIT 7.105, 42.9%). In four locations, some nurses neglected to
wash or sanitize their hands before donning gloves or before each subsequent regloving.
Staff in six of seven applicable medication preparation and administration areas
demonstrated appropriate administrative controls and protocols (MIT 7.106, 85.7%). In
one location, medication nurses did not describe the process they followed when
reconciling newly received medication and the MAR with the corresponding physician’s
order.
Staff in two of seven applicable medication areas used appropriate administrative
controls and protocols when distributing medications to their patients (MIT 7.107,
28.6%). In five locations, we observed one or more of the following deficiencies:
medication nurses did not distribute medications to patients within required time
frames; medication nurses did not always verify patients’ identification using a secondary
identifier; medication nurses did not reliably observe patients while they swallowed
direct observation therapy medications; medication nurses did not follow the CCHCS
care guide when administering Suboxone medication; and during insulin administration,
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we observed some medication nurses did not properly disinfect the medication vial’s port
prior to withdrawing medication.46
Pharmacy Protocols
Pharmacy staff followed general security, organization, and cleanliness management
protocols in its remote and main pharmacy (MIT 7.108, 100%), and staff properly stored
nonrefrigerated medications (MIT 7.109, 100%)
The institution properly stored refrigerated or frozen medications in one of two
pharmacies (MIT 7.110, 50.0%). In the remote pharmacy, we found an unsanitary freezer.
The pharmacist-in-charge (PIC) correctly accounted for narcotic medications stored in
both MCSP pharmacies (MIT 7.111, 100%).
We examined 12 medication error reports and found the PIC timely and correctly
processed all reports (MIT 7.112, 100%).
Nonscored Tests
Our compliance team interviewed patients in restrictive housing units to determine
whether they had immediate access to their prescribed asthma rescue inhalers or
nitroglycerin medications. Of the applicable patients interviewed, six of 10 indicated they
had access to their rescue medications. Two patients reported running out of their rescue
inhalers, while two other patients lost their rescue inhalers. Of the four patients, three
patients had not informed any staff members, and one patient had informed medical staff
one day prior. We promptly notified the CEO of this concern, and health care
management immediately issued replacement rescue inhalers to the patients (MIT 7.999).
46 Suboxone is a medication containing buprenorphine and naloxone. Suboxone is used to treat opioid
dependence and addiction.
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Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
1 17 7 5.6%
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
16 9 0 64.0%
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 2 23 0 8.0%
required time frames? (7.003)
For patients received from a county jail: Were all medications ordered by the
institution’s reception center provider administered, made available, or delivered to N/A N/A N/A N/A
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
12 13 0 48.0%
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 3 7 0 30.0%
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 11 0 4 100%
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 3 9 3 25.0%
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 7 3 41.7%
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 11 1 3 91.7%
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 3 4 8 42.9%
medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 6 1 8 85.7%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 2 5 8 28.6%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization, and
2 0 0 100%
cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
2 0 0 100%
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
1 1 0 50.0%
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
2 0 0 100%
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting protocols?
12 0 0 100%
(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): 60.1%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: If the
patient had an existing medication order upon arrival, were medications 6 9 10 40.0%
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- 8 0 2 100%
packet required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
13 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 12 1 0 92.3%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient N/A N/A N/A N/A
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical and nursing leadership should develop strategies to ensure chronic
care, hospital discharge, and en route patients receive their medications
timely and without interruption. Leadership should implement remedial
measures as appropriate.
• Nursing leadership should develop strategies to ensure nursing staff
document patient medication refusals in medication administration records,
as described in CCHCS policy and procedures, and should implement
remedial measures as appropriate.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
out patients quickly. The OIG rated this indicator solely according to the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Proficient (91.1%)
MCSP performed very well in preventive services. Staff performed outstandingly in
administering TB medications to patients as prescribed, offering patients an influenza
vaccine for the most recent influenza season, and offering colorectal cancer screening for
patients ages 45 through 75. They also performed excellently in monitoring patients
taking TB medications and screening patients annually for TB. However, staff needed
improvement in offering required 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
13 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 12 1 0 92.3%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
24 1 0 96.0%
(9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
25 0 0 100%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care
7 5 13 58.3%
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): 91.1%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Health care leadership should determine the root cause(s) for challenges to
timely providing immunizations to chronic care patients and should
implement appropriate remedial measures.
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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
MCSP’s overall nursing performance was sufficient. Compared with Cycle 6, MCSP had
similar results this cycle. We found nurses performed good assessments and
interventions for patient transfers and patients returning from hospitalizations. Although
overall nursing performance was sufficient, we identified opportunities for improvement
with nursing assessments and interventions in emergency care and in the outpatient
clinics as discussed below. Factoring all the information, the OIG rated this indicator
adequate.
Case Review Results
We reviewed 160 nursing encounters in 54 cases. Of the nursing encounters we reviewed,
81 occurred in the outpatient setting, and 58 were sick call requests. We identified 61
nursing performance deficiencies, seven of which were significant.47
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.
47 Deficiencies occurred in cases 1–6, 9–11, 21, 23–26, 34–42, 44–47, 50, 51, 53, 55, 57, and 58–60. Significant
deficiencies occurred in cases 2, 6, 10, 23, 50, 58 and 60.
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OIG clinicians identified 37 outpatient nursing deficiencies, four of which were
significant.48 We found nurses generally performed appropriate assessments and
interventions. However, we identified opportunities for improvement with nurses
completing thorough assessments, appropriately scheduling patients with symptomatic
complaints, initiating co-consultations with providers when conditions warranted, and
providing patient education. The following are examples:
• In case 1, the nurse reviewed the patient’s sick call request with complaints
of having problems going to the bathroom and stated the tissue paper was
irritating him. However, the nurse triaged the complaint as asymptomatic
and scheduled the patient for a nurse face-to-face assessment in 14 days
instead of one business day for a symptomatic complaint.
• In case 10, the nurse assessed the patient for complaints of rectal bleeding
when wiping with intermittent burning discomfort. The patient also reported
lifelong intermittent vomiting several times per week after eating meals.
However, the nurse did not inquire about the time of symptom onset of rectal
bleeding and did not co-consult with the provider to report patient
symptoms.
• In case 53, the nurse assessed the patient for complaints of constant right
shoulder pain. However, the nurse did not provide patient education before
the patient was discharged back to housing. Similar deficiencies occurred in
cases 10, 21, 25, 26, 38, 47, 55, 57, and 59.
• In case 60, the nurse reviewed the patient’s sick call request with
symptomatic complaints of stomach cramps, vomiting, and diarrhea. The
nurse did not schedule a same day evaluation for the patient’s urgent
symptoms. One day later, the nurse assessed the patient who reported having
abdominal discomfort, vomiting, and three to five loose stools a day for the
past three days. The nurse used the nursing protocol for diarrhea and
administered antidiarrheal medication. However, the nurse did not perform a
complete abdominal assessment, such as listening to bowel sounds, assessing
if abdomen was tender or nontender, or inquiring when the patient last
vomited to include a description of the content. In addition, the nurse did not
co-consult with the provider for further evaluation and a plan of care.
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. OIG clinicians found nurses mostly documented patient care appropriately.
Emergency Services
OIG clinicians reviewed 40 urgent and emergent events. We found nurses responded to
emergency events timely, generally performed good assessments, and documented
48 Outpatient nursing deficiencies occurred in cases 1, 3, 9, 10, 21, 25, 26, 37–42, 44–47, 50, 51, 53, 55 and 57–60.
Significant deficiencies occurred in cases 10, 50, 58 and 60.
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appropriately. However, we found staff needed improvement in a few areas, which we
detail further in the Emergency Services indicator.
Hospital Returns
OIG clinicians reviewed 13 events involving patients returning from off-site hospitals or
emergency rooms and found nurses performed excellent nursing assessments, which we
detail further in the Transfers indicator.
Transfers
OIG clinicians reviewed nine cases involving transfer-in and transfer-out processes. The
nurses performed good assessments, completed the health care screening, and initiated
nurse and provider appointments within required time frames. However, we found when
patients transferred out of the facility, the nurses did not always document pending
specialty referrals and appointments. However, these deficiencies did not impact the
overall care of the patient. Please refer to the Transfers indicator for further details.
Specialized Medical Housing
OIG clinicians did not have any case review samples for specialized medical housing to
review during our review period.
Specialty Services
We reviewed 10 events in which patients returned from an off-site specialty service
appointment for specialty procedures and consultations.49 Nurses performed good
assessments when patients returned from off-site specialty appointments. We identified
two minor deficiencies.50 One deficiency related to documentation, and in the other
deficiency, the nurse did not obtain the specialist’s recommendations following the
patient’s return from the appointment.
Medication Management
OIG clinicians reviewed 152 events involving medication management and found most
nurses administered medications to patients as prescribed. However, we identified
opportunities for improvement in medication continuity for patients on chronic care
medications and for patients returning from the hospital. Please refer to the Medication
Management indicator for additional details.
Clinician On-Site Inspection
OIG clinicians interviewed various nursing staff and supervisors. We attended organized
and collaborative clinic huddles on A Yard and E Yard, and found staff were familiar with
their patient care population.
Leadership reported A Yard had the largest patient population at MCSP. The A Yard
primary care team consisted of three primary care RNs (PCRNs), two providers, two
49 Specialty Service nursing encounter events occurred in cases 3, 10, 24, 25, and 26.
50 Specialty Service nursing performance deficiencies occurred in cases 1 and 3.
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medical assistants (MAs), and four LVNs. The A Yard nursing staff reported seeing an
average of 10 to 16 patients per day. At the time of our inspection, the provider had a
backlog of 147 patients, and the RN had a backlog of 100 patients, due to recent
restriction of patient movement following an increase in altercations within the patient
population and threats on staff. However, staff shared their plans to mitigate the backlog,
including bundling appointments and scheduling weekend clinics.
We interviewed the supervising registered nurse, who shared the process for auditing the
quality of nursing care. The supervisor reported completing 10 sick call audits per nurse
each month and conducting one-to-one training to address any deficiencies identified.
The supervisor also shared some of the challenges they faced, including patient refusals
of medical appointments, medications, and specialty appointments.
The staff reported MCSP had implemented an incarcerated peer support specialist
program. The specialist role included confirming attendance with patients who were
scheduled for any medical appointments or for picking up prescribed medications. The
peer support specialist would notify the nurse of any patient refusals, and the nurse
would schedule a follow-up appointment and provide patient education.
We interviewed nursing leadership, who reported on several quality improvement
projects in progress, such as the patient disengagement project, the 9-1-1 activation
project, and the Suboxone nonadherence project.51 They also shared details of an
upcoming pilot project requiring the primary care nurses to respond to medical
emergency alarms on the yard.
At the time of our inspection, MCSP was fully staffed, except for one registry RN
vacancy. The staff at MCSP expressed feeling supported by nursing leadership and
reported a cohesive working relationship with custody staff.
51 The patient disengagement project addressed patients refusing medical services as well as on-site and off-site
specialty appointments. To address the refusals, the institution’s leadership used the incarcerated peer support
specialist program to act as a liaison between the patient and the nursing and physician care teams to help
decrease refusals.
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Recommendations
• Nursing leadership should determine the challenges to ensuring nurses
perform appropriate triage of sick call requests, complete and thorough face-
to-face assessments, and co-consults with providers when needed. Nursing
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
Similar to Cycle 6, case review found MCSP providers continued to deliver generally
acceptable care. Providers always documented nurse co-consultations and generally
managed chronic conditions appropriately. They usually ordered laboratory tests,
medications, and specialty consultations as medically indicated. However, providers
sometimes performed incomplete assessments and inconsistently reviewed or addressed
abnormal laboratory results and vital signs, which accounted for most of the severe
deficiencies. After considering all aspects of care, the OIG rated this indicator adequate.
Case Review Results
The OIG clinicians reviewed 129 medical provider encounters and identified 40
deficiencies related to provider performance, 12 of which were significant.52 In addition,
we reviewed the quality of care in 25 comprehensive case reviews. Of these 25 cases, we
found 24 adequate, and one inadequate.
Outpatient Assessment and Decision-Making
Providers generally made appropriate assessments and sound decisions for their patients.
Most of the time, they documented good histories, formulated differential diagnoses,
ordered appropriate tests, provided care with the correct diagnosis, and referred patients
to the proper specialists when needed. We identified 26 deficiencies related to providers’
assessments and decision-making, seven of which were significant.53 We discuss these
seven significant deficiencies below.
OIG clinicians identified the following significant deficiencies related to performing
incomplete subjective or objective assessments:
52 Deficiencies occurred in cases 3, 9, 12, 13, 15–17, 19, 24, and 25–30. Significant deficiencies occurred in cases
3, 9, 12, 16, 26, and 27.
53 Deficiencies occurred in cases 3, 9, 12, 13, 16, 24, 25, and 27–30. Significant deficiencies occurred in cases 3, 9,
16, and 27.
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• In case 3, the patient complained of urinary frequency and nocturia.54 The
provider prescribed prazosin for LUTS (lower urinary tract symptoms) but
did not perform a prostate exam.55
• In case 27, the provider evaluated the patient at an appointment to discuss
the patient’s stress test result and cardiology appointment. The provider
reviewed and documented the patient’s low blood pressure, which was
significantly lower than the patient’s previous two blood pressure readings.
However, the provider did not perform a subjective assessment to inquire
about symptomatic hypotension or perform an objective assessment. Also, in
this same case, the provider later evaluated the patient at another
appointment to follow up on the patient’s blood pressure. However, the
provider again did not perform a subjective or objective assessment.
OIG clinicians identified the following significant deficiencies related to questionable or
poor decision-making, resulting from not addressing abnormal vital signs or abnormal
laboratory results:
• In case 3, the provider reviewed laboratory test results, which included an
abnormally low ferritin test level.56 The provider sent a patient notification
letter stating, “will follow up with the next chronic care visit for abnormal
results.” However, the patient’s next scheduled chronic care appointment
was set for four months later. In the interim, the patient submitted a sick call
request to see the provider to discuss the test results. The provider did not
consider scheduling a sooner appointment to discuss abnormal results with
the patient. Also, in this same case, the patient was scheduled to see the
provider at a follow-up appointment to discuss abnormal laboratory test
results after the patient went to the emergency department at a local
hospital. However, the provider did not discuss the laboratory test results
with the patient.
• In case 9, the provider evaluated the patient for “refusing mobility vest” and
documented the patient’s elevated blood pressure. One month prior, the
provider also documented an elevated blood pressure for the patient.
However, the provider did not address these abnormal blood pressures or
order a future recheck.
• In case 16, the provider ordered an increased dosage of the patient’s diuretic,
hydrochlorothiazide.57 However, the provider did not consider ordering
laboratory tests to measure for potential effects of this medication on the
patient’s kidney function and electrolyte levels. In addition, the provider did
54 Nocturia is excessive nighttime urination.
55 Prazosin is a medication used to treat symptoms from an enlarged prostate.
56 A ferritin test measures the amount of a blood protein that stores iron in the body.
57 Hydrochlorothiazide is a blood pressure medication used to treat blood pressure by removing fluid and salt
from the body through the urine. This may result in changes in kidney function and electrolytes.
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not adjust the patient’s diabetic regimen, despite the Hemoglobin A1c
(HbA1c) worsening from 9.1 to 10.8.58
Review of Records
Providers generally reviewed medical records carefully; however, we identified seven
deficiencies in which providers did not appear to have sufficient knowledge of the
medical record, three of which were significant. We discuss the three significant
deficiencies below:59
• In case 12, the provider evaluated the patient at an episodic care and sick call
follow-up appointment. The provider documented the “Hematologist
recommended to have a target INR of 2-3.”60 However, the provider did not
review the MAR to see the patient had two warfarin prescriptions with two
different target INR goals.61 Also, in this same case, the provider documented
having reviewed a supratherapeutic INR level of 3.8.62 The provider adjusted
one warfarin prescription and ordered a goal INR level of 2.5 to 3.5. However,
the provider did not review the MAR, and as a result, was not aware of the
second warfarin prescription with a different INR goal of 2 to 3.
• In case 26, the provider signed medication orders for glaucoma eye drops,
brimonidine and dorzolamide-timolol, as part of the patient’s post-
hospitalization medication reconciliation. However, the provider did not
confirm the medication directions and signed incorrect orders.
Emergency Care
Providers appropriately managed patients in the TTA with urgent or emergent
conditions. OIG clinicians identified no provider care deficiencies in emergency care.
We further discuss urgent and emergent patient care in the Emergency Services
indicator.
Chronic Care
In most instances, providers appropriately managed patients’ chronic health conditions.
Providers performed well in managing chronic medical conditions such as hypertension,
diabetes, asthma, hepatitis C infection, and cardiovascular disease. However, we
identified four deficiencies, one of which was significant, as described below:63
58 Hemoglobin A1c (HbA1c) is a blood test that measures the average plasma glucose over the previous 12
weeks. For most patients with diabetes, the HbA1c goal is 7 percent or less.
https://www.cdc.gov/diabetes/diabetes-testing/prediabetes-a1c-test.html
59 Deficiencies related to reviewing records occurred in cases 12 and 26. Three significant deficiencies occurred
within the two cases.
60 INR, International Normalized Ratio, is a laboratory test to measure the body’s blood clotting. This test is
used to monitor the effectiveness of blood thinning medications such as warfarin.
61 Warfarin is a blood thinning medication requiring laboratory testing to monitor its effectiveness.
62 Supratherapeutic refers to a level of drug that is higher than the maximum level for treatment.
63 Deficiencies occurred in cases 15–17, and 19. A significant deficiency occurred in case 16.
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• In case 16, the provider evaluated the patient at a chronic care appointment
and documented the patient’s blood pressure as “at goal” despite the
patient’s elevated blood pressure. One day prior, the patient’s blood pressure
was also elevated. However, the provider did not address these abnormal
blood pressure readings or order a follow-up blood pressure appointment. In
addition, the provider documented the patient’s diabetes as "Not at goal," but
did not document a plan for addressing it.
Specialty Services
MCSP providers generally ordered appropriate specialty consultations when medically
indicated. When specialists offered recommendations, the providers usually followed
these recommendations appropriately and reviewed specialty reports timely. We
identified only one significant deficiency related to specialty care:
• In case 16, the endocrinology specialist evaluated the patient at a diabetes
and hyperlipidemia follow-up appointment. The specialist recommended the
patient complete laboratory work in three months and “F/U when lab back.”
However, the provider did not order this follow-up appointment, and the
specialist did not see the patient again during the review period. In addition,
the endocrinology specialist recommended a cardiologist evaluate the patient
for uncontrolled hypertension. However, the provider ordered the cardiology
consultation more than five weeks later.
We also discuss specialty services in the Specialty Services indicator.
Documentation Quality
Documentation is important because it shows the provider’s thought process during
clinical decision-making. Providers almost always accurately documented encounters
with patients and communication with nurses. We identified only two minor deficiencies
in provider documentation.64
Patient Notification Letters
After providers interpret laboratory test results, they are responsible for generating test
result notification letters to inform patients of the laboratory test results and of the
necessary next steps. Providers inconsistently sent notification letters to patients. When
they did, the letters did not always contain the four elements required by policy: date of
the test, reviewing provider’s name, whether the results were within normal limits, and
whether a provider follow-up appointment is required and will be scheduled. We
identified this type of deficiency in 13 of the 25 detailed cases we reviewed; however,
none were significant.65
We discuss patient notification letters further in the Health Information Management
indicator.
64 Minor deficiencies occurred in cases 24 and 29.
65 Minor deficiencies occurred in cases 10, 12–18, 22, 23, 27, 29, and 30.
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Provider Continuity
Provider continuity was generally good, with most providers working on a yard for long
periods of time, and in some cases, for years.
Clinician On-Site Inspection
OIG clinicians met with the institution’s two Chief Physician & Surgeons (CP&Ss) and
providers. The CME was not present at the time of the inspection due to preplanned
leave. The CP&Ss reported having two full-time employee vacancies; one vacancy was
filled with a registry provider, and the other vacancy had a promising candidate. They
reported having previously hired providers through “word of mouth” and having
“excellent” provider staff morale.
We discussed challenges to delivering care at MCSP. The CP&Ss and the providers
described access to specialty care as a significant challenge. Because MCSP provided care
to transgender patients, the institution needed to be able to access specialists in this
field. However, these specialists had limited availability. In addition, some specialists
were located a far distance away from the institution, at times necessitating patient travel
of two and a half hours.
We also discussed patient care with the providers, who consistently reported feeling
supported by their physician supervisors. Providers stated their CP&Ss were easily
accessible for questions and directly involved in their practices, as the CP&Ss sometimes
evaluated patients. All the providers reported having good morale, noting their
collegiality with one another and the accessibility of their CP&Ss as drivers of their job
satisfaction.
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Recommendations
• Medical leadership should determine the root cause(s) of challenges with
thorough provider assessments and review of medical records and should
implement remedial measures as appropriate.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing,
monitoring, and intervening for medically complex patients requiring close medical
supervision. Our inspectors also evaluated the timeliness and quality of provider and
nursing intake assessments and care plans. We assessed staff members’ performance in
responding promptly when patients’ conditions deteriorated and looked for good
communication when staff consulted with one another while providing continuity of
care.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Not Applicable
The institution did not have any medical admissions to the specialized medical housing
unit during our review or inspection period for our review. Therefore, the OIG did not
assess this indicator, and instead, designated it as not applicable.
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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
N/A N/A N/A N/A
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
N/A N/A N/A N/A
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 N/A N/A N/A N/A
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call N/A N/A N/A N/A
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 N/A N/A N/A N/A
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): N/A
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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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. The OIG
clinicians focused on the institution’s performance in providing needed specialty care.
Our clinicians also examined specialty appointment scheduling, providers’ specialty
referrals, and medical staff’s retrieval, review, and implementation of any specialty
recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (81.4%)
Case review found MCSP performed satisfactorily in providing specialty services for its
patients. Completion of provider follow-up appointments after specialty consultations
always timely occurred. Although patients almost always received timely access to
specialty appointments, we found two significant delays. In addition, while providers
frequently reviewed specialty reports timely, we identified a pattern of deficiencies in
which an on-site specialist did not forward consultation reports to the providers. In
considering the balance of the care provided and deficiencies identified, the OIG rated
the case review component of this indicator adequate.
Compliance showed MCSP performed satisfactorily in this indicator. High-priority,
medium-priority, and routine-priority specialty services usually occurred timely.
Generally, staff received, and providers endorsed, specialty reports within required time
frames. However, preapproved specialty services for newly arrived patients only
intermittently occurred timely. 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 115 events related to Specialty Services, including 103 specialty
consultations and procedures, 10 nursing encounters, and two provider encounters. We
identified 22 deficiencies in this category, three of which were significant.66
Access to Specialty Services
MCSP performed variably in providing timely access to specialists. Compliance testing
showed MCSP usually completed high-priority (MIT 14.001, 80.0%), medium-priority
(MIT 14.004, 86.7%), and routine-priority (MIT 14.007, 80.0%) specialty appointments
timely. However, staff performed poorly with ensuring preapproved specialty access
within required time frames for patients who transferred into the institution (MIT 14.010,
45.0%).
66 Deficiencies occurred in cases 1, 3, 9, 12, 15–18, 20–23, 25–27, and 29. Significant deficiencies occurred in
cases 16, 22, and 23.
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OIG clinicians identified two deficiencies with specialty care access, both of which were
significant. The following is an example:
• In case 23, the provider ordered the rheumatology specialty appointment.67
However, medical staff did not process the order timely, and the appointment
did not occur within the review period as ordered.
Provider Performance
MCSP provided excellent access to providers after specialty service appointments.
Compliance testing showed the institution always completed timely provider follow-up
appointments (MIT 1.008, 100%). OIG clinicians similarly identified no late provider
follow-up appointments. We also found providers generally ordered appropriate specialty
consultations, followed specialty recommendations, and performed appropriate specialty
follow-up assessments. We identified only one significant deficiency related to provider
care.68 We discuss this further in the Provider Performance indicator.
Nursing Performance
MCSP nurses performed well in assessing patients who returned to the facility from off-
site specialty appointments. OIG clinicians identified only two minor deficiencies.69
Health Information Management
MCSP sufficiently managed specialty reports. Compliance testing showed staff generally
received specialty reports and providers endorsed routine-priority (MIT 14.008, 80.0%),
high-priority (MIT 14.002, 85.7%), and medium-priority (MIT 14.005, 85.7%) services
reports within required time frames. Staff also performed very well in scanning specialty
reports timely (MIT 4.002, 86.7%).
OIG clinicians identified a total of 18 health information management (HIM)
deficiencies, only one of which was significant as follows:70
• In case 22, HIM staff scanned the telemedicine endocrinology specialty
report into EHRS. However, HIM staff did not forward the report to the
provider.71
Of the remaining 17 deficiencies, 13 related to an on-site specialist not forwarding the
specialty consultation reports to the providers.72
67 Rheumatology is a medical specialty involving the evaluation and management of patients with autoimmune,
inflammatory, and joint conditions.
68 A significant deficiency occurred in case 16.
69 Minor deficiencies occurred in cases 1 and 3.
70 Deficiencies occurred in cases 1, 3, 9, 12, 15–18, 20–22, 25–27, and 29. A significant deficiency occurred in case
22.
71 Endocrinology is a medical specialty involving the evaluation and management of glandular and hormonal
conditions, including diabetes mellitus and thyroid diseases.
72 Deficiencies in which the on-site specialist did not forward the report to the provider for endorsement
occurred in cases 1, 3, 9, 15–18, 20–22, 25, 26, and 29.
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We also discuss this in the Health Information Management indicator.
Clinician On-Site Inspection
OIG clinicians discussed specialty services with the supervising registered nurses (SRNs)
covering off-site specialty services, utilization management, on-site specialty services,
and telemedicine specialty services. The HIM supervisors reported triaging all high-
priority referrals to at least two specialty providers and following up with the specialists
every other day until the soonest appointment date was secured. The specialty service
SRNs also reported regularly monitoring the tracking log for appointments scheduled out
of compliance. If able to switch appointments to better meet compliance dates, the
specialty SRNs exchanged patient appointments as needed. They mentioned patient
refusal of specialty services requiring long-distance travel as a challenge to completing
some specialty consultations.
We discussed difficult-to-obtain specialty services with medical staff. Some staff
members reported difficulty in obtaining cosmetic and medical consultations related to
gender affirming care. Other staff members cited transporting patients a long distance as
a hurdle to providing these services. We also discussed the forwarding of on-site specialty
reports to providers. MCSP leadership reported the on-site specialists were now expected
to send their reports to the providers.
The specialty service SRNs reported no staff shortages during the review period. Other
SRNs covered their positions as needed. However, they tried to arrange their leave time
so both were never off from work at the same time.
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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 12 3 0 80.0%
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 12 2 1 85.7%
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? 5 2 8 71.4%
(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 13 2 0 86.7%
Service? (14.004)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 12 2 1 85.7%
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? 8 0 7 100%
(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 12 3 0 80.0%
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
9 11 0 45.0%
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
19 1 0 95.0%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
16 4 0 80.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 81.4%
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
31 0 14 100%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
26 4 15 86.7%
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
• Health care leadership should determine the root cause(s) of challenges to the
timely provision of preapproved specialty appointments for transfer patients
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 Adequate (79.0%)
MCSP’s overall performance was satisfactory in this indicator. MCSP scored excellently
in addressing patient’s medical grievances, maintaining health care staff licenses and
certifications, and providing the required onboarding and clinical competency for all
newly hired nursing staff. However, MCSP needed improvement in several areas. The
Emergency Medical Response Review Committee (EMRRC) only intermittently
completed required checklists. Medical staff did not timely complete several initial
patient death reports. In addition, staff conducted medical emergency response drills
with incomplete documentation. Furthermore, the nurse educator did not ensure all
nurses who administer medications complete their clinical competency testing in a
timely manner. Lastly, physician managers only sporadically completed probationary and
annual performance appraisals timely. These findings are set forth in the table on the
next page. Based on the overall Administrative Operations compliance score result, the
OIG rated this indicator adequate.
Compliance Testing Results
Nonscored Results
At MCSP, 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 nine patients, we found
no evidence in the submitted documentation that the preliminary mortality reports
had been completed. These reports were overdue at the time of the OIG’s inspection
(MIT 15.998).
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Compliance Score Results
Table 19. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the This is a nonscored test. Please refer to the
institution meet RCA reporting requirements? (15.001) discussion in this indicator.
Did the institution’s Quality Management Committee (QMC) meet monthly?
6 0 0 100%
(15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
8 4 0 66.7%
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 4 0 0 100%
procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during each
watch of the most recent quarter, and did health care and custody staff 0 3 0 0
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
6 3 0 66.7%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
7 3 0 70.0%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
4 13 0 23.5%
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 20 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 2 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
1 0 0 100%
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): 79.0%
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 MCSP
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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. MCSP Case Review Sample Sets
Sample Set Total
Anticoagulation 3
Death Review/Sentinel Events 3
Diabetes 3
Emergency Services – CPR 5
Emergency Services – Non-CPR 3
High Risk 5
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 28
Specialty Services 4
64
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Table B–2. MCSP Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 6
Anticoagulation 7
Arthritis/Degenerative Joint Disease 9
Asthma 11
Cancer 1
Cardiovascular Disease 9
Chronic Kidney Disease 8
Chronic Pain 11
Cirrhosis/End-State Liver Disease 5
COPD 7
COVID-19 6
Deep Venous Thrombosis/Pulmonary Embolism 2
Diabetes 14
Gastroesophageal Reflux Disease (GERD) 12
Hepatitis C 20
HIV 2
Hyperlipidemia 26
Hypertension 28
Mental Health 37
Seizure Disorder 2
Sleep Apnea 4
Substance Abuse 28
Thyroid Disease 2
257
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Table B–3. MCSP Case Review Events by Program
Diagnosis Total
Diagnostic Services 216
Emergency Care 70
Hospitalization 27
Intrasystem Transfers In 14
Intrasystem Transfers Out 11
Outpatient Care 459
Specialty Services 148
945
Table B–4. MCSP Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 25
RN Reviews Detailed 17
RN Reviews Focused 39
Total Reviews 81
Total Unique Cases 64
Overlapping Reviews (MD & RN) 17
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Appendix C: Compliance Sampling Methodology
Mule Creek 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 35 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 25 OIG Q: 4.005 • See Health Information Management
Community (Medical Records) (returns from
Hospital community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001 – 003 Radiology 10 Radiology Logs • Appointment date
(90 days – 9 months)
• Randomize
• Abnormal
MITs 2.004 – 006 Laboratory 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 0 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 35 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 25 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 25 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 14 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 25 OIG Q: 4.005 • See Health Information Management
Community Hospital (Medical Records) (returns from
community hospital)
MIT 7.004 RC Arrivals — N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 10 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies OIG inspector • Identify and inspect clinical & med
Areas by test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site clinical
Preparation and by test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 2 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 12 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit 10 On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications medication listing medications for IPs housed in
restricted units
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 96
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 13 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
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 97
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 0 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 N/A 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
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 98
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 20 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 4 LGB meeting • Quarterly meeting minutes
minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 99
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations (continued)
MIT 15.103 Death Reports 9 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 17 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 20 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 9 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 100
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Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7, Mule Creek State Prison | 101
California Correctional Health Care Services’
Response
Office of the Inspector General, State of California Inspection Period: February 2024 – July 2024 Report Issued: October 2025
Cycle 7
Medical Inspection Report
for
Mule Creek State Prison
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Shaun Spillane
Chief Deputy Inspector General
STATE of CALIFORNIA
October 2025
OIG