OIG
North Kern State Prison Cycle 7 Medical Inspection Report
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Cycle 7, North Kern 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 7
Population-Based Metrics 10
HEDIS Results 10
Recommendations 12
Indicators 15
Access to Care 15
Diagnostic Services 23
Emergency Services 29
Health Information Management 35
Health Care Environment 41
Transfers 49
Medication Management 56
Preventive Services 64
Nursing Performance 67
Provider Performance 74
Reception Center 81
Specialized Medical Housing 87
Specialty Services 93
Administrative Operations 100
Appendix A: Methodology 103
Case Reviews 104
Compliance Testing 107
Indicator Ratings and the Overall Medical Quality Rating 108
Appendix B: Case Review Data 109
Appendix C: Compliance Sampling Methodology 113
California Correctional Health Care Services’ Response 121
November 25, 2024, OIG Response to November 18, 2024, Letter
Regarding NKSP Report 122
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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Illustrations
Tables
1. NKSP Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. NKSP Master Registry Data as of June 2023 8
3. NKSP Health Care Staffing Resources as of June 2023 9
4. NKSP Results Compared With State HEDIS Scores 11
5. Access to Care 20
6. Other Tests Related to Access to Care 21
7. Diagnostic Services 27
8. Health Information Management 38
9. Other Tests Related to Health Information Management 39
10. Health Care Environment 47
11. Transfers 53
12. Other Tests Related to Transfers 54
13. Medication Management 61
14. Other Tests Related to Specialized Services 62
15. Preventive Services 65
16. Reception Center 84
17. Other Tests Related to Reception Center 85
18. Specialized Medical Housing 91
19. Specialized Services 97
20. Other Tests Related to Specialized Services 98
21. Administrative Operations 101
A–1. Case Review Definitions 104
B–1. NKSP Case Review Sample Sets 109
B–2. NKSP Case Review Chronic Care Diagnoses 110
B–3. NKSP Case Review Events by Program 111
B–4. NKSP Case Review Sample Summary 111
Figures
A–1. Inspection Indicator Review Distribution for NKSP 103
A–2. Case Review Testing 106
A–3. Compliance Sampling Methodology 107
Photographs
1. Indoor Waiting Area With Individual Treatment Modules 41
2. Cluttered Examination Room 42
3. The Clinic Lacked Auditory Privacy During Clinical Encounters 42
4. Expired Medical Supply Dated April 11, 2023 43
5. Medical Supplies Stored Directly on the Floor 43
6. Staff Prefilled the Clinic’s Tool Control Inventory Report One Day Early 44
7. Dusty Stretcher 45
8. An Insect Found in a Clinic Drawer 45
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care that 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: November 2022 – April 2023 Report Issued: November 2024
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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 North Kern State
Prison (NKSP), the institution had not been delegated back to the department by the
receiver. However, on January 12, 2024, the Receiver delegated this institution back to the
department.
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 November 2022 to April 2023.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between May 2022 and November 2022, emergency cardiopulmonary resuscitation
reviews between June 2022 and April 2023, and transfer reviews between October 2022 and April 2023.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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Summary: Ratings and Scores
We completed the Cycle 7 inspection of NKSP in September 2023. OIG inspectors
monitored the institution’s delivery of medical care that occurred between
November 1, 2022, and April 30, 2023.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at NKSP adequate. quality at NKSP inadequate.
The OIG clinicians (a team of physicians and nurse consultants) reviewed 55 cases, which
contained 723 patient-related events. They performed quality control reviews; their
subsequent collective deliberations ensured consistency, accuracy, and thoroughness.
Our OIG clinicians acknowledged institutional structures that catch and resolve mistakes
that may occur throughout the delivery of care. After examining the medical records, our
clinicians completed a follow-up on-site inspection in September 2023 to verify their
initial findings. The OIG physicians rated the quality of care for 20 comprehensive case
reviews. Of these 20 cases, our physicians rated 18 adequate, and two inadequate.
To test the institution’s policy compliance, our compliance inspectors (a team of
registered nurses) monitored the institution’s compliance with its medical policies by
answering a standardized set of questions that measure specific elements of health care
delivery. Our compliance inspectors examined 454 patient records and 1,335 data points
and used the data to answer 101 policy questions. In addition, we observed NKSP’s
processes during an on-site inspection in July 2023.
The OIG then considered the results from both case review and compliance testing, and
drew overall conclusions, which we report in 14 health care indicators.5
5 The indicator for Prenatal and Postpartum Care did not apply to NKSP.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. NKSP Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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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 one adverse event at NKSP during the Cycle 7 inspection as follows:
• In case 9, the previously healthy patient arrived at the triage and
treatment area (TTA) with symptoms of fever, body aches, chills,
coughing up blood, and shortness of breath. The patient was placed
in COVID-19 isolation for 22 days without appropriate nursing
assessments or being evaluated by a provider. On Day 22, the patient
was found unresponsive in his cell and could not be revived. The
coroner determined the patient died of pneumonia, a generally
treatable medical condition. Had the patient received appropriate
medical care, he would not have died.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 11 of the 14
indicators applicable to NKSP. Of these 11 indicators, OIG clinicians rated 10 adequate
and one inadequate. The OIG physicians also rated the overall adequacy of care for each
of the 20 detailed case reviews they conducted. Of these 20 cases, 18 were adequate and
two were inadequate. In the 723 events reviewed, we found 267 deficiencies, 43 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 NKSP:
• Provider initial health assessments and treatments on patients newly
arrived to NKSP were usually appropriate and thorough.
• Patients had good access to outpatient and specialized medical
housing providers.
• The supervising registered nurse (SRN) who oversaw the TTA, the
receiving and release (R&R) area, and the specialty services area
conducted daily huddles with the specialty team to ensure all new
transfers or patients returning from the hospital had the appropriate
6 For a further discussion of an adverse event, see Table A–1.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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follow-up care, and staff timely reconciled medications and specialty
referrals.
Our clinicians found the following weaknesses at NKSP:
• NKSP leadership and staff had different understandings of urgent
and emergency transport time frames.
• Providers sometimes ordered inappropriate time frames for specialty
referrals.
• NKSP staff did not immediately activate emergency medical services
(EMS) when medically indicated or when a provider ordered a patient
to be transferred to the hospital.
• The emergency response clinical reviews by the SRN, the chief
medical executive (CME), and the chief nursing executive (CNE)
often did not identify assessments, interventions, or documentation
deficiencies that the OIG found.
Compliance Testing Results
Our compliance inspectors assessed 11 of the 14 indicators applicable to NKSP. Of these
11 indicators, our compliance inspectors rated three proficient, one adequate, and seven
inadequate. We tested policy compliance in Health Care Environment, Preventive
Services, and Administrative Operations as these indicators do not have a case review
component.
NKSP showed a high rate of policy compliance in the following areas:
• Medical staff performed proficiently in scanning request for health
care services forms and hospital discharge reports into patients’
electronic medical records within required time frames.
• The institution completed high-priority, medium-priority, and
routine-priority specialty services within required time frames. The
institution retrieved specialists’ reports, and providers reviewed
these reports timely.
• Nursing staff thoroughly completed initial health screening forms
for newly arrived patients at NKSP. In addition, for patients
transferring out of NKSP, nursing staff ensured all required
medications, durable medical equipment, and documentation were
processed completely and timely.
• Providers performed well in evaluating patients with chronic care
conditions, patients returning from community hospitals, and
patients returning from specialty service appointments within
specified time frames. Moreover, NKSP referred patients timely to
their providers upon arrival at the institution.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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NKSP showed a low rate of policy compliance in the following areas:
• The institution did not consistently provide routine and STAT
(immediate) laboratory services within required time frames.
• Providers did not often communicate results of diagnostic services
timely. Most patient notification letters communicating these results
were missing information as to whether the results were within
normal limits.
• Health care staff did not consistently follow universal hand hygiene
precautions during patient encounters or medication preparation
and administration.
• Patients did not always receive their chronic care medications within
required time frames. We found poor medication continuity for
patients returning from hospitalization, for patients admitted to
specialized medical housing, and for patients transferring into and
laying over at NKSP.
Institution-Specific Metrics
North Kern State Prison (NKSP) is a medium-security prison located in Delano in Kern
County. As a reception center, its mission is to process and classify incoming patients
received from county jails by evaluating their medical and mental health needs,
evaluating their security levels and program requirements, and determining appropriate
institutional placement prior to their transfer to other State facilities. NKSP operates
multiple clinics in which staff members handle nonurgent requests for medical services.
The institution also treats patients who need urgent or emergent care in its TTA and
provides inpatient care in its correctional treatment center (CTC). NKSP has been
designated a basic care institution by California Correctional Health Care Services
(CCHCS); basic facilities are typically located in rural areas, far away from tertiary care
centers and specialty care providers whose services would likely be used frequently by
higher-risk medical patients. Due to the institution’s remote location and its basic health
care status, in general, healthier patients are placed in this institution. As of September
17, 2024, the department reports on its public tracker that 50 percent of NKSP’s
incarcerated population is fully vaccinated for COVID-19 while 63 percent of NKSP’s
staff is fully vaccinated for COVID-19.7
7 For more information, see the department’s statistics on its website page titled Population COVID-19
Tracking.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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In June 2023, the Health Care Services Master Registry showed that NKSP had a total
population of 4,117. A breakdown of the medical risk level of the NKSP population as
determined by the department is set forth in Table 2 below.8
Table 2. NKSP Master Registry Data as of June 2023
Medical Risk Level Number of Patients Percentage*
High 1 53 1.3%
High 2 170 4.1%
Medium 1,546 37.6%
Low 2,348 57.0%
Total 4,117 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from
the CCHCS Master Registry dated 6-19-23.
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: November 2022 – April 2023 Report Issued: November 2024
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According to staffing data the OIG obtained from CCHCS, as identified in Table 3 below,
NKSP had zero vacant executive leadership positions, 0.5 primary care provider
vacancies, 0.2 nursing supervisor vacancies, and 17.8 nursing staff vacancies.
Table 3. NKSP Health Care Staffing Resources as of June 2023
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 5.0 12.5 13.2 145.4 176.1
Filled by Civil Service 5.0 12.0 13.0 127.6 157.6
Vacant 0 0.5 0.2 17.8 18.5
Percentage Filled by Civil Service 100% 100% 100% 88.0% 89.5%
Filled by Telemedicine 0 1.0 0 0 1.0
Percentage Filled by Telemedicine 0 8.0% 0 0 0.6%
Filled by Registry 0 0 0 10.0 10.0
Percentage Filled by Registry 0 0 0 7.6% 5.7%
Total Filled Positions 5.0 12.0 13.0 137.6 167.6
Total Percentage Filled 100% 96.0% 98.5% 94.6% 95.2%
Appointments in Last 12 Months 0 2.0 3.0 16.0 21.0
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 0 6.0 6.0
Adjusted Total: Filled Positions 5.0 12.0 13.0 131.6 161.6
Adjusted Total: Percentage Filled 100% 96.0% 98.5% 90.5% 91.7%
* 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 June 19, 2023, from California Correctional
Health Care Services.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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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 NKSP’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. Currently, only one HEDIS
measure is available for review: poor HbA1c control, which measures the percentage of
diabetic patients who have poor blood sugar control. NKSP’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)— NKSP’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. NKSP had a 23 percent influenza
immunization rate for adults 18 to 64 years old and an influenza immunization rate of
zero for adults 65 years of age and older.9 The pneumococcal vaccination rate was not
applicable.10
Cancer Screening
Statewide comparative data were not available for colorectal cancer screening; however,
we include these data for informational purposes. NKSP had a 54 percent colorectal
cancer screening rate.
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. For this
institution, our sample size for this test was insufficient, leading to a rate of “not applicable.”
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Table 4. NKSP Results Compared With State HEDIS Scores
NKSP 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%) ‡,§ 10% 38% 28% 20%
HbA1c Control (< 8.0%) ‡ 66% – – –
Blood Pressure Control (< 140/90) ‡ 94% – – –
Eye Examinations 85% – – –
Influenza – Adults (18 – 64) 23% – – –
Influenza – Adults (65 +) 0 – – –
Pneumococcal – Adults (65 +) 0 – – –
Colorectal Cancer Screening 54% – – –
Notes and Sources
* Unless otherwise stated, data were collected in July 2023 by reviewing medical records from a sample of
NKSP’s population of applicable patients. These random statistical sample sizes were based on a 95 percent
confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication
titled Medi-Cal Managed Care External Quality Review Technical Report, dated July 1, 2021 – June 30, 2022
(published April 2023); https://www.dhcs.ca.gov/dataandstats/reports/Documents/CA2021-22-MCMC-
EQR-TR-VOL1-F1.pdf.
‡ For this indicator, the entire applicable NKSP 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: November 2022 – April 2023 Report Issued: November 2024
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Recommendations
As a result of our assessment of NKSP’s performance, we offer the following
recommendations to the department:
Diagnostic Services
• Medical leadership should determine the root cause(s) of challenges
encountered when collecting, receiving, and notifying providers of
STAT and routine laboratory results timely and implement remedial
measures as appropriate.
• The department should consider developing strategies to ensure that
providers create patient letters when they endorse tests results and that
patient letters contain all elements required by CCHCS policy.
Emergency Services
• Nursing leadership should determine the challenges that prevent
staff from immediately initiating EMS when indicated or when the
provider orders the patient to be transported to the community
hospital. Leadership should implement remedial measures as
indicated.
• Nursing leadership should determine the root cause(s) of challenges
that prevent nurses from performing complete assessments, timely
interventions, and thorough documentation. Leadership should
implement remedial measures as indicated.
• Nursing leadership should determine the root cause(s) of challenges
SRNs face in completing thorough reviews of urgent and emergent
events in which patients transfer to the community hospital and
implement remedial measures as indicated.
• Executive leadership should determine the challenges preventing the
EMRRC from reviewing all unscheduled transports to off-site
hospitals and properly identifying all deficiencies in the quality of
nursing or provider performance, policy, procedures, and form
completion. Executive leadership should implement remedial
measures as indicated.
Health Care Environment
• Medical leadership should analyze the root cause(s) of staff not
following all required universal hand hygiene precautions and should
implement necessary remedial measures.
• Executive leadership should analyze the root cause(s) of staff not
following equipment and medical supply management protocols and
should implement necessary remedial measures.
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• Nursing leadership should determine the root cause(s) of staff not
ensuring the EMRBs are regularly inventoried and sealed, and of
staff failing to properly complete the monthly logs and should
implement necessary remedial measures.
• Executive leadership should determine the root cause(s) of unclean
clinics, medical storage rooms, and restrooms and should implement
necessary remedial measures.
Medication Management
• The institution should develop and implement measures to ensure
staff timely make available and administer medications to patients
and document the medication administration record (MAR)
summaries, as described in CCHCS policy and procedures.
• Nursing leadership should determine the challenges for nursing staff
in documenting patient refusals in the MAR, as described in CCHCS
policy and procedures, and implement remedial measures as
appropriate.
Preventive Services
• Nursing leadership should develop and implement measures to ensure
nursing staff consistently perform patient monitoring as described in
CCHCS Care Guides, and nursing staff completely address TB signs and
symptoms in their patient monitoring.
• Medical leadership should determine the challenges to timely
providing immunizations to chronic care patients and implement
remedial measures as appropriate.
• Medical leadership should develop strategies to ensure patients at
the highest risk of coccidioidomycosis (Valley Fever) are transferred
in a timely manner and implement remedial measures as appropriate.
Nursing Performance
• Nursing leadership should determine the challenges that prevent
outpatient nurses from performing complete assessments and
implement remedial measures as indicated, such as training staff.
Provider Performance
• Medical leadership must familiarize themselves with the different
time frames associated with emergency transport versus urgent
transport as established in state and local policy. Medical leadership
should also develop and implement strategies to educate and train
providers on the differences in these time frames to ensure orders
designation appropriate transport levels.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 14
• Medical leadership should determine the cause(s) of challenges to
providers ordering specialty services for medically appropriate
priorities and time frames and implement remedial measures as
appropriate.
• Medical leadership should determine the cause(s) of challenges to
providers completing appropriate medical documentation, including
on-call progress notes and updated patient medical problem lists and
implement remedial measures as appropriate.
Reception Center
• Medical leadership should determine the challenges providers
encounter when completing H&P examinations within required time
frames, as required by CCHCS policy, and implement remedial
measures as appropriate.
• NKSP leadership should determine the root cause(s) of patients not
receiving Reception Center laboratory services timely and implement
remedial measures as appropriate.
Specialized Medical Housing
• Nursing leadership should determine the challenges preventing CTC
nursing staff from completing thorough patient assessments,
including PICC line care, and from completing thorough
documentation. Nursing leadership should implement remedial
measures as appropriate.
• Nursing leadership should determine the challenges preventing CTC
nursing staff from completing the call light system rounding
checklist every 15 minutes as per the local operating procedures and
should implement remedial measures as appropriate.
• The institution should ascertain the root cause(s) related to why
medications are not consistently available and administered in a
timely manner to specialized medical housing patients and should
implement remedial measures as appropriate.
Specialty Services
• Medical leadership should determine the root cause(s) of providers
not ordering specialty services within medically appropriate time
frames and should implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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Indicators
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing
patients with timely clinical appointments. Our inspectors reviewed scheduling and
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
specialists. Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (84.7%)
Case review found NKSP’s access to care was good. Nursing often assessed patients
timely. Outpatient and specialized medical housing provider access was excellent.
Provider follow-up after high-priority specialty services, hospitalization, and receiving
emergent or urgent care in the TTA was also very good. However, we identified
deficiencies with providers ordering inappropriate time frames for specialty services. In
addition, we found nearly one half of transfer-in patients were not seen by a provider
within the required time frames. Overall, the OIG rated the case review component of
this indicator adequate.
Compliance testing showed NKSP performed satisfactorily in this indicator. Staff
performed excellently in reviewing patient sick call requests and in timely completing
provider follow-up appointments for patients returning from specialty services and
hospitalizations. Nurses performed satisfactorily in completing face-to-face encounters,
offering provider follow-up appointments for patients transferring into the institution,
delivering follow-up appointments for patients with chronic care conditions, and
completing provider follow-up sick call appointments. However, NKSP scored low in
maintaining patient sick call forms in housing units. Based on the overall compliance
score result, the OIG rated the compliance component of this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 156 provider, nursing, urgent or emergent care (TTA), specialty,
and hospital events that required the institution to generate appointments. We identified
19 deficiencies relating to Access to Care, five of which were significant.11
Access to Care Providers
Compliance testing showed NKSP performed satisfactorily in providing both chronic
care face-to-face follow-up appointments (MIT 1.001, 80.0%) and nursing-to-provider sick
11 Deficiencies occurred in cases 2, 8, 18, 21, 23–27, 32, 33, 37, 39, 46, 48, 54, and 55. Significant deficiencies
occurred in cases 8, 24, 27, 32, and 54.
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call referrals (MIT 1.005, 85.7%). Case review found only one minor deficiency related to
provider access in the outpatient setting.12
Access to Specialized Medical Housing Providers
NKSP provided excellent access to specialized medical housing providers. Compliance
testing showed NKSP’s specialized medical housing patients always received written
history and physical (H&P) exams within required time frames (MIT 13.002, 100%). Case
review similarly did not identify any deficiencies.
Access to Clinic Nurses
NKSP performed well in patient access to nurse sick calls and provider-to-nurse referrals.
Compliance testing showed nurses often reviewed patient requests for medical services
the day of receipt (MIT 1.003, 93.3%), and assessed patients within one business day for
symptomatic health care requests (MIT 1.004, 83.3%). Our clinicians reviewed 40 nursing
sick call requests in 32 cases. We identified nine deficiencies related to delayed or
missing nurse appointments, two of which were significant.13
• In case 24, the patient submitted a sick call request for a suspected
arm infection. Instead of being seen the same day, the patient was
scheduled and seen by the nurse two business days later, placing the
patient’s health at risk.
• In case 50, the nurse triaged a sick call request for a patient who
complained of falling in the shower and experiencing decreased
sensation in the lower part of his body. The nurses did not see the
patient the same day to assess his symptoms and possible injuries.
Access to Specialty Services
NKSP’s performance in patient access to specialists was mixed. Compliance testing
determined a satisfactory completion rate of high-priority appointments (MIT 14.001,
80.0%), good completion rate of medium-priority appointments (MIT 14.004, 86.7%), and
excellent completion rate of routine-priority appointments (MIT 14.007, 100%). NKSP
performed satisfactorily in scheduling high-priority follow-up appointments with
specialists (MIT 14.003, 83.3%) and excellently in scheduling medium- and routine-
priority follow-up specialty appointments (MIT 14.006, 100%, and MIT 14.009, 100%).
Case review clinicians reviewed 64 specialty services events and found 13 deficiencies
related to specialty access. 14 Only four deficiencies directly related to appointment
scheduling, one of which was significant.15 The deficiency is discussed further in the
Specialty Services indicator.
12 A deficiency occurred in case 18.
13 Deficiencies occurred in cases 17, 23, 24, 37, 39, 46, 48, and 50.
14 Deficiencies occurred in cases 1, 16, 21, 25, 53–55. Significant deficiencies occurred in cases 16, 25, 54, and 55.
15Access to care scheduling deficiencies occurred in cases 21, 25, 54, and 55. A significant deficiency occurred in
case 54.
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Cycle 7, North Kern State Prison | 17
Our clinicians identified nine deficiencies related to providers ordering specialty services
outside medically necessary time frames or ordering the incorrect type of service. Five of
those deficiencies were significant and are discussed further in the Provider
Performance and Specialty Services Indicator.
Follow-Up After Specialty Services
Compliance testing revealed nearly all provider follow-up appointments after high-
priority specialty services occurred within the required time frames (MIT 1.008, 93.3%).
Case review did not identify any deficiencies in this area.
Follow-Up After Hospitalization
NKSP performed excellently in ensuring providers saw patients after hospitalizations
(MIT 1.007, 92.0%). Case review did not identify any deficiencies in this area.
Follow-Up After Urgent or Emergent Care (TTA)
Providers generally saw their patients following a TTA event as ordered. OIG clinicians
assessed 23 TTA events and providers always saw the patients in follow up as ordered.
Follow-Up After Transferring Into NKSP
Compliance testing showed satisfactory performance in access to intake appointments
for newly arrived patients (MIT 1.002, 83.3%). Case reviewers, however, found NKSP
performed poorly with provider access. We reviewed 12 reception center and transfer-in
cases and identified six deficiencies, three of which were significant.16 Examples include
the following:
• In case 8, the high-risk patient with an intracranial shunt arrived to
NKSP from a county jail and was evaluated by a provider 13 days late.
• In case 27, the high-risk medical transfer-in patient did not receive
the initial provider evaluation until 25 days after arrival.
• In case 32, the high-risk medical reception center patient was
evaluated by a provider 18 days late.
Clinician On-Site Inspection
Our case review clinicians spoke with NKSP’s executive leadership and schedulers
regarding the institution’s access to care.
NKSP had six main clinics, designated as A, B, C, D, D6, and M, in addition to the
diagnostic reception center. NKSP also operated a TTA and a CTC. Staffing included
four midlevel providers and eight physicians. A midlevel provider was assigned to the
CTC and TTA and overseen by a provider, who also performed rounds one time a week.
Leadership discussed the new reception center, called “diagnostics,” which processed 350
to 400 new patients per week. At the time of our inspections, we were informed this new
16 Deficiencies occurred in cases 2, 8, 26, 27, 32, and 33. Significant deficiencies occurred in cases 8, 27, and 32.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 18
area was expected to house nurses, providers, dental, mental health, radiology, and
custody staff and was nearing completion. It was also expected to streamline and
expedite the new intake, transfer-in, and transfer-out processes.
At the on-site case review, some providers mentioned they were assigned to the new
diagnostics center and had been performing initial provider appointments within the
first 24 hours of patient arrival as part of intake streamlining. Some expressed concern
this placed them at risk of COVID-19 infection because incoming patients were just
beginning COVID-19 quarantine upon arrival. We did not observe either patients or
providers using personal protective equipment (PPE).
During the OIG case review, we identified several delays in provider initial patient
assessments. Those delays were often due to providers not seeing patients who were in
the initial 10- to 14-day COVID-19 quarantine. However, nurses performed their
respective patient care duties on quarantine patients during this same time frame.
The schedulers reported a backlog in both provider episodic and chronic care
appointments during the review period, with only 68 percent completed by compliance
dates. This was similar to the OIG compliance testing results. The backlog was due to an
increase in urgent care appointments, a shortage of providers, COVID-19 concerns, and
patient class compatibility. Medical leadership confirmed NKSP was short one to two
providers during our review period. Two additional providers had been appointed over
the previous 12 months.
Furthermore, in response to the backlog, medical leadership had increased the number of
patients each provider was scheduled to see each day and added as-needed weekend and
evening provider clinics. Physician providers were assigned to see 12 patients per eight-
hour schedule and 16 patients per 10-hour schedule plus nurse co-consultations. Mid-
level providers were scheduled for 10 patients in eight-hour workdays and 14 patients in
10-hour workdays. The physician providers stated they often also completed several co-
consultations a day as well as at least two add-on patients on their schedules, and they
expressed concern about the sustainability of this schedule. Regarding the add-on clinics,
providers from NKSP and other institutions could volunteer for these extra shifts and
were given hourly shift compensation. The providers expressed appreciation for the
financial incentive of the additional work hours. They reported this had reduced the
backlog and improved access since the review period.
Scheduling also discussed the backlog of ISUDT evaluations and appointments due to an
increase in patients arriving on medication assisted treatment (MAT) from the county
jails and CCHCS’s full expansion of the program. Despite full expansion, a backlog of
over 1,200 licensed clinical social worker initial ISUDT assessments existed as of
September 2023. In addition, per the new arrival on MAT workflow, providers from
CCHCS headquarters addiction medicine team were supposed to manage the new
arrivals on MAT; however, they were short on providers and new arrivals on MAT were
not being seen within compliance time frames. The responsibility for seeing these
patients, whose care was already out of compliance, then became the responsibility of
NKSP primary care providers when these patients were added to their schedules.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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Compliance On-Site Inspection
Four of six housing units randomly tested at the time of inspection had access to health
care services request forms (CDCR 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. In
addition, we found an unsecured designated health care services request form collection
box in one of the two housing units.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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Compliance Score Results
Table 5. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent chronic
care visit within the health care guideline’s maximum allowable interval or 20 5 0 80.0%
within the ordered time frame, whichever is shorter? (1.001)
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 20 4 1 83.3%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
28 2 0 93.3%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
25 5 0 83.3%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
6 1 23 85.7%
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 0 0 30 N/A
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
23 2 0 92.0%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
42 3 0 93.3%
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): 84.7%
* 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.
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Table 6. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the 0 0 20 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 12 8 0 60.0%
to 07/2022) or five working days (effective 07/2022)? (12.004)
Was a written history and physical examination completed within the
10 0 0 100%
required time frame? (13.002)
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 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 1 9 83.3%
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 15 0 0 100%
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 2 0 13 100%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
We offer no specific recommendations for this indicator.
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Cycle 7, North Kern State Prison | 23
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 (61.7%)
Case review found NKSP performed well in diagnostic services. Staff generally completed
radiology and laboratory tests timely. Providers endorsed results within required time
frames. However, providers often did not send patient results notification letters, or the
letters were missing the required elements. After reviewing all aspects, the OIG rated the
case review component of this indicator adequate.
NKSP’s overall compliance testing scored low for this indicator. Staff performed
excellently in providing radiology services as well as retrieving and reviewing radiology,
laboratory, and pathology results. However, testing showed providers needed
improvement in generating patient notification letters with all required key elements for
diagnostic results. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 150 diagnostic events and found 59 deficiencies, none of which
were significant. Of these 59 deficiencies, we found 55 related to health information
management (HIM) including patient results notification letters not being sent to the
patient, letters missing required components, or late provider endorsements. Only four
deficiencies were due to late or missed test completion.17
Test Completion
Compliance testing showed NKSP performed excellently in completing radiology tests
within the required time frames (MIT 2.001, 100%). In contrast, NKSP performance in
completing routine laboratory testing worsened from 100 percent in Cycle 6 to half that
score in Cycle 7 (MIT 2.004, 50%). Additionally, the institution continued to perform
poorly in STAT laboratory test completion and results receipt (MIT 2.007, 20.0%). Nursing
staff also performed poorly in notifying the provider within 30 minutes of receiving STAT
laboratory test results (MIT 2.008, 20.0%). Case review identified four deficiencies in
laboratory test completion, none of which were significant, and one STAT radiology test
17 Deficiencies occurred in cases 1, 2, 8–18, 20, 22–25, and 53–55.
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that was completed timely.18 This is discussed further in Clinician On-Site Inspection
below.
Health Information Management
Both case review and the compliance team found NKSP staff retrieved routine laboratory
and diagnostic results promptly and sent them to providers for review. Providers
performed very well in endorsing both radiology (MIT 2.002, 90.0%) and laboratory (MIT
2.005, 90.0%) results timely.19
The providers always endorsed STAT laboratory test results within the required time
frames (MIT 2.009, 100%). However, compliance testing showed, as in Cycle 6, nurses
continued to perform poorly in timely notifying providers of STAT laboratory studies
(MIT 2.008, 20.0%). Our clinicians did not find any deficiencies in the two STAT events in
case review.
Compliance testing showed NKSP performed excellently in pathology results retrieval
(MIT 2.010, 100%) and in provider review (MIT 2.011, 100%). However, providers rarely
communicated pathology results to patients timely (MIT 2.012, 20.0%). Case reviewers
identified two pathology results in their samples and found, in both cases, the providers
timely retrieved, reviewed, and informed patients of the results. However, we found one
minor deficiency for missing letter components.20
NKSP performed poorly in communicating test results to patients. Compliance testing
showed providers scored low in communicating radiology and laboratory test results to
the patients (MIT 2.003, 50.0% and MIT 2.006, 0.0%). Case review identified 50
deficiencies related to patient notification letters. Of these, 28 deficiencies related to
providers failing to notify patients of their test results within policy time frames. All but
three of the missing notification letter deficiencies were due to one provider. Several
providers were involved in the 22 additional deficiencies with patient notification letters
missing at least one of the required elements.21
Clinician On-Site Inspection
OIG clinicians met with medical leadership and available laboratory and radiology staff.
The relatively new chief support executive (CSE) met with us in lieu of the diagnostic
services supervisor, who was out on long-term leave.
The NKSP radiology equipment was replaced in January 2023 and had been in good
working order since that time. The X-ray services were available each weekday. During
several months of the case review period, NKSP was short one radiology technician, but
no backlog of services resulted. NKSP radiology technicians scheduled both the on-site
and off-site specialty radiology appointments and were responsible for obtaining those
reports.
18 Deficiencies occurred in cases 8, 17, 23, and 53.
19 Five deficiencies occurred in cases 18, 23, 53, and 54.
20 Case review identified pathology events requiring follow up in cases 18 and 25.
21 Deficiencies occurred in cases 1, 9–18, 20, 22–25, and 55.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 25
The new reception center, also called “diagnostics center,” planned to offer X-ray
services for intake and screening assessments on newly arrived patients. The physical
space for X-ray was built at the time of our inspection; however, equipment installation
was pending.
On-site specialty imaging services were offered by outside vendors. Ultrasound and MRI
clinics were offered once a month, while CT scans were offered every other week.22
Leadership discussed requiring more frequent on-site specialty imaging services than
were currently available, but they did their best to work within these limitations.
Both on-site and specialty imaging radiology as well as laboratory test results interfaced
directly with the EHRS.23 Once received, the results automatically routed to the providers
for review and endorsement. Diagnostics staff reported they were not responsible for
monitoring provider endorsement of laboratory studies or ensuring patient results
notification letters were complete and sent.
Laboratory testing completion rates varied between OIG compliance and case review.
This may be due to slightly different sample periods. Compliance testing case samples for
this indicator ranged from September 2022 through January 2023 and resulted in lower
completion rates than case review. The case review inspection period was November 1,
2022, to April 30, 2023. NKSP reported a significant backlog of more than 2,600 laboratory
studies involving more than 290 patients in November and December 2022. By January
and February 2023, which were included in the case review period, laboratory testing
completion rates improved to 50 percent with no backlog. Completion rates continued to
improve to 94 percent by the end of the case review period.
Diagnostics leadership described many challenges to meeting compliance time frames:
• NKSP had a large number of new intake patients: 300 to 400 per
week. New intake patients required intake screening laboratory tests
and multiple COVID–19 tests be completed before release from
quarantine.
• COVID-19 quarantine and class restrictions made it difficult for
laboratory services to access patients and complete tests timely.
• A shortage of laboratory staff during the period contributed to a
significant backlog and overtime continued to be utilized to meet
compliance time frames.
When asked about staffing shortages and sustainability of continued overtime
assignments for existing staff, leadership mentioned difficulty hiring lower-level
administrative and technical staff, such as laboratory technicians, due to multiple factors.
These factors included a high crime rate in NKSP’s location, regular periods of inclement
weather, and lack of close institutions of higher education and professional schools. In
22 An MRI is a magnetic resonance imaging scan. A CT scan is a computed, or computerized, tomography
imaging scan.
23 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 use the system to communicate with one another.
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addition, leadership reported pay rates offered by CCHCS were not competitive; potential
candidates could make more money in a more desirable environment, and several
competing employers also offered telework options.
Since June 2023, a laboratory technician had been housed within the new diagnostics
center and could process patient intake laboratory tests during the intake process,
reducing the obstacles presented by COVID-19 quarantine and transport issues.
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Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
5 5 0 50.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
5 5 0 50.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
0 10 0 0
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
2 8 0 20.0%
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
2 8 0 20.0%
staff notify the provider within the required time frames? (2.008)
Laboratory: Did the health care provider endorse the STAT laboratory
10 0 0 100%
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within the
10 0 0 100%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
2 8 0 20.0%
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 61.7%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the root cause(s) of challenges
encountered when collecting, receiving, and notifying providers of
STAT and routine laboratory results timely and implement remedial
measures as appropriate.
• The department should consider developing strategies to ensure that
providers create patient letters when they endorse tests results and
that patient letters contain all elements required by CCHCS policy.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
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Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed emergency medical services by examining the timeliness and
appropriateness of clinical decisions made during medical emergencies. Our evaluation
included examining the emergency medical response, cardiopulmonary resuscitation
(CPR) quality, triage and treatment area (TTA) care, provider performance, and nursing
performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services.
The OIG assessed the institution’s emergency services mainly through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
NKSP performed poorly in emergency services. In Cycle 7, OIG clinicians identified more
deficiencies than in Cycle 6. A pattern continued from Cycle 6 to Cycle 7 with delays in
emergency medical services (EMS) notification. NKSP nurses did not perform well during
emergency events. Nursing staff generally responded promptly to emergent events.
However, the nurses did not always perform an initial thorough assessment and did not
always reassess patient vital signs and symptoms. Providers generally performed well in
urgent and emergent care. Compliance testing showed the institution’s EMRRC
meetings were not held timely, incident packages were incomplete, and the CME and
CNE or designee did not complete clinical reviews of the unscheduled transports. Our
clinicians reached similar findings with the CNE and CME not completing clinical
reviews in all the urgent and emergent cases. We identified further opportunities for
improvement in the institution’s ability to identify assessment, intervention, and
documentation deficiencies. Factoring all aspects, the OIG rated this indicator
inadequate.
Case Review Results
OIG clinicians reviewed 16 cases with 26 urgent or emergent events. We found 32
deficiencies, 11 of which were significant.24
Emergency Medical Response
NKSP staff generally responded promptly to emergencies throughout the institution.
OIG clinicians reviewed seven cases that required CPR.25 Staff initiated CPR and notified
24 Deficiencies occurred in cases 1, 2, 4, 8, 9, 19–21, 23, and 24. Significant deficiencies occurred in cases 1, 4, 9,
19, 20, 23, and 24.
25 CPR events occurred in cases 3–9.
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TTA staff timely. However, we identified a pattern of delays in activating EMS, ranging
from 12 minutes to an hour.26 The following are examples:
• In case 4, the patient reported snorting another patient’s Suboxone
and shortly became lethargic.27 Nursing staff administered two doses
of Narcan out in the field and transported the patient to the TTA.
While in the TTA the patient required CPR. However, nursing staff
did not activate EMS until 12 minutes after administering the initial
dose of Narcan.
• In case 9, staff activated a medical alarm for an unresponsive patient.
The registered nurse (RN) attempted to respond via the emergency
response vehicle but documented the vehicle’s engine would not
start. Subsequently, the RN walked and arrived at the patient 14
minutes after the medical alarm was activated.
• In case 24, the patient sustained facial and head trauma including
bleeding in the mouth. Nursing staff called for EMS an hour after the
provider ordered the patient to be transferred urgently via
ambulance to the community hospital. The ambulance arrived 23
minutes after the nursing staff called for EMS.
Provider Performance
Providers generally performed well in urgent and emergent situations. They usually were
available to nursing staff, made accurate diagnoses, and completed documentation. Of
the 26 emergency events, the OIG clinicians identified four deficiencies, two of which
were significant:28
• In case 19, the patient presented with chest tightness and low heart
rate. The provider ordered the patient sent to the hospital urgently
by ambulance instead of emergently. This led to a delay in patient
care and placed the patient at risk.
• In case 20, the patient presented with severe abdominal pain, nausea,
and vomiting. The provider ordered the patient sent to the hospital
urgently via ambulance to rule out appendicitis, rather than
emergently. Due to this order, the patient was not transported to the
hospital until over 1.5 hours after the emergency event occurred.
Nursing Performance
NKSP nurses did not perform well during emergency events. The nurses did not always
assess and monitor their patients to include reassessing vital signs and reassessing the
patients’ symptoms.
26 The pattern of delays in activating EMS occurred in cases 1, 4, and 24.
27 Suboxone is a medication to treat narcotic dependence.
28Deficiencies occurred in cases 1, 19, 20, and 23. Significant deficiencies occurred in cases 19 and 20.
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• In case 1, the patient arrived at NKSP from the county jail. During
the reception center intake process, the patient reported
experiencing chest pain. The patient was immediately transported to
the TTA for further evaluation. However, the TTA nursing staff did
not assess chest pain onset, reassess the chest pain severity for more
than an hour after the initial assessment, or reassess the pulse. In
addition, the nursing staff activated EMS 12 minutes after the
provider ordered the patient to be transported emergently via
ambulance to the community hospital.
• In case 19, staff provided emergency services for the patient with
complaints of chest tightness and a low heart rate with symptoms.
The TTA nursing staff did not reassess the vital signs for
approximately an hour while the patient was in the TTA. In addition,
the nursing staff did not reassess chest tightness severity or chest
pain for two hours while waiting for EMS to arrive in TTA.
• In case 23, the patient was evaluated in the TTA with an elevated
blood pressure, severe headache, and moderate chest pain. The TTA
RN did not initiate nitroglycerin per the chest pain protocol.
Secondly, the TTA RN consulted with the provider 25 minutes after
the patient arrived to the TTA for a further care plan. Lastly, the
TTA RN, did not reassess the chest pain and headache severity after
the initial assessment in the TTA.
• In case 24, the patient sustained facial trauma including bleeding in
the mouth. The LVN responded to the patient and documented
active bleeding in the mouth. The LVN did not initiate bleeding
control measures and did not inquire about or document how the
injury occurred. Additionally, the record was unclear on whether,
prior to transporting the patient to the TTA, nursing appropriately
assessed the patient to determine if the patient should have had
cervical/lumbar spine immobilization and alternative transportation
to the TTA, instead of via wheelchair, to prevent further injuries.
Nursing Documentation
TTA nurses usually documented sufficiently for emergent events, although
documentation was lacking for the timeline of emergency events, the times EMS was
requested, and the gauge of intravenous (IV) needles used.29 These deficiencies did not
affect overall patient care.
Emergency Medical Response Review Committee
Compliance testing showed NKSP’s EMRRC performed poorly. In most cases, NKSP did
not review cases timely, the incident package was incomplete, or the institution did not
complete the clinical review portion for the CNE and CME or designee (MIT 15.003,
16.7%). Our clinicians found the EMRRC met monthly; however, the EMRR audits the
SRNs performed usually did not identify training issues. In addition, our clinicians
29 Deficiencies in TTA nursing documentation occurred in cases 1, 2, 9, 20, 21, and 24.
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Cycle 7, North Kern State Prison | 32
reached similar findings to the compliance team with the CNE and CME or designees
not completing the clinical review portion of the EMRR checklist in all the urgent and
emergent cases reviewed. Finally, none of the clinical reviews conducted by NKSP SRNs
captured any of the multiple opportunities for improvement identified by our clinicians.
Our clinicians reviewed 16 cases with urgent and emergent events and found 10
deficiencies, three of which were significant involving the EMRR checklist or the
EMRRC.30 The significant cases are provided below.
• In case 4, the SRN performed a clinical review for a patient who
reported snorting another patient’s Suboxone, became unresponsive
requiring multiple doses of Narcan and CPR, and died at the
institution. Nurses did not initiate EMS until 12 minutes after
administering the initial dose of Narcan. In addition, the CME and
the CNE did not perform a clinical review of the event. However,
neither the SRN nor the EMRRC identified any training issues with
this emergency event.
• In case 19, staff provided emergency services to a patient with chest
pain and a low heart rate, who was transported to the community
hospital. The SRN performed a clinical review on this patient and
identified no training issues. TTA nursing staff did not reassess the
vital signs for approximately an hour while the patient was in the
TTA, and they did not reassess chest tightness severity or pain for
two hours while waiting for EMS to arrive in the TTA. In addition,
neither the CME nor CNE performed a clinical review and the
EMRRC identified no training issues with this emergency event.
• In case 24, the patient was found bleeding in the mouth with facial
injuries and was transferred to the community hospital. The CNE
and CME did not perform a clinical review. In addition, the SRN who
performed the review did not identify any concerns with the LVN
failing to initiate bleeding control measures and inquire about or
document how the injury occurred at the scene. In addition, the
record was unclear on whether, prior to transport, nursing staff
appropriately assessed the patient to determine if he should have had
cervical/lumbar spine immobilization and alternative transportation
to the TTA due to the injuries. Lastly, nursing staff did not notify
EMS until approximately an hour after the provider ordered the
transfer to the community hospital.
Clinician On-Site Inspection
OIG clinicians interviewed RNs, an SRN, MDs, the CNE, and the CME. The TTA had
three bays and was staffed with two RNs on each shift. A provider for TTA was available
on-site from 7:00 a.m. to 9:00 p.m., and available via phone from 9:00 p.m. to 7:00 a.m.
During the on-site inspection, the clinicians were informed the institution had one
emergency response vehicle (ERV). During our review period, one case involved a delay of
30 The EMRR and EMRRC deficiencies occurred in cases 1, 2, 4, 8, 19–21, 23, and 24. Significant deficiencies
occurred in cases 4, 19, and 24.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 33
14 minutes for TTA nursing response to an unresponsive patient due to the ERV not
working. The CNE reported, after this emergency event, the ERV was taken for repairs
and, the EMR coordinator and healthcare captain consulted with NKSP fire department
to respond to medical emergencies until the ERV was repaired. In the interim, the ERV
cart was used pending ERV repair. The ERV failure prompted a change in the ERV
operational procedure. The TTA custody officer would drive the ERV around the facility
at the start of each shift to ensure functionality and complete the monthly travel log. The
TTA RNs were responsible for checking the ERV for cleanliness.
OIG clinicians identified a pattern of delays with notifying EMS after providers ordered a
higher level of care transport. Both medical leadership and providers stated their belief
that no difference occurs in urgent versus emergency ambulance time frames. However,
the CNE informed our clinicians, for urgent transfers, they wait for custody to assemble
their team prior to calling for the ambulance to prevent the ambulance staff arriving
before custody has their team assembled. The CNE further noted the urgent ambulance
transfers can take up to two hours to arrive at the institution. The TTA RN reported the
custody team normally takes 20 minutes to assemble, and the ambulance arrives
approximately 30 minutes after notification. The CNE reported she would address this
current practice with a new policy because the staff should not wait for either the
Request for Authorization of Temporary Removal for Medical Treatment form to be
completed or for custody to have their team available and assembled prior to contacting
the ambulance to prevent potential delay of interventions from the ambulance staff.
The CNE also reported the new EMR training had started the third week of August 2023
and the EMR was to be implemented at the end of January 2024.
The clinicians informed the CNE and TTA RN that the EMRR checklist provided during
the reviews was a one-page form, which had an area for the CNE and the CME or
designee’s clinical review, but the form contained no designated area for a summary of
the event, as required. The TTA SRN reported the EMRR checklist only had one page, the
staff documented the summary of the events as needed, and they emailed the EMR
checklist to the CME and CNE for review and confirmation but did not obtain their
signatures.
The TTA SRN reported having recently started using the Emergency Medical Response
and Unscheduled Transport Event Checklist to document the summary of events. NKSP
also shifted to using DocuSign for the clinical reviews from the CME and CNE or
designee for the EMR checklist.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 34
Recommendations
• Nursing leadership should determine the challenges that prevent
staff from immediately initiating EMS when indicated or when the
provider orders the patient to be transported to the community
hospital. Leadership should implement remedial measures as
indicated.
• Nursing leadership should determine the root cause(s) of challenges
that prevent nurses from performing complete assessments, timely
interventions, and thorough documentation. Leadership should
implement remedial measures as indicated.
• Nursing leadership should determine the root cause(s) of challenges
SRNs face in completing thorough reviews of urgent and emergent
events in which patients transfer to the community hospital and
implement remedial measures as indicated.
• Executive leadership should determine the challenges preventing the
EMRRC from reviewing all unscheduled transports to off-site
hospitals and properly identifying all deficiencies in the quality of
nursing or provider performance, policy, procedures, and form
completion. Executive leadership should implement remedial
measures as indicated.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 35
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 NKSP performed well in health information management this cycle.
However, NKSP had performed better in Cycle 6. Although staff performed well in
emergency documentation, we found deficiencies such as incomplete hospital discharge
reports, late endorsement of specialty reports, illegible signatures, and lack of continuity
of care. After reviewing all aspects, the OIG rated the case review component of this
indicator adequate.
NKSP performed exceptionally well overall in compliance testing for this indicator. Staff
excelled in scanning patient sick call requests and endorsing hospital records. The
institution also performed well in retrieving and scanning hospital records, labeling,
scanning medical records into the correct patient files, and scanning specialty
documents. Based on the overall compliance score result, the OIG rated the compliance
component of this indicator proficient.
Case Review and Compliance Testing Results
We reviewed 723 events and found 79 deficiencies related to health information
management. Of these 79 deficiencies, only one was significant.31
Hospital Discharge Reports
Compliance testing showed NKSP staff retrieved hospital records and satisfactorily
scanned them into the medical record (MIT 4.003, 85.0%). Providers always reviewed the
hospital reports properly (MIT 4.005, 100%). Case review found similar results with the
hospital records scanning and review. However, our clinicians found some hospital
documents were scanned timely but were missing important diagnostic test results.32
31 Deficiencies occurred in cases 9–18, 20, 22–25, and 54. A significant deficiency occurred in case 32.
32 The deficiencies occurred in cases 19 and 24.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 36
Specialty Reports
NKSP performed satisfactorily in retrieving specialty reports (MIT 4.002, 83.3%).
Providers performed excellently in endorsing high-priority specialty reports (MIT 14.002,
100%); however, provider endorsements of medium- and routine-priority specialty reports
were only satisfactory (MIT 14.005, 80.0% and MIT 14.008, 80.0%).
Our clinicians reviewed 43 specialty reports and identified 10 deficiencies, none of which
were significant.33 The 10 deficiencies ranged from late specialty record retrieval to late
provider endorsements. We discuss these findings further in the Specialty Services and
Provider Performance indicators.
Diagnostic Reports
As in Cycle 6, staff performed excellently in this cycle with retrieving, and with providers
reviewing, laboratory and diagnostic results. However, in Cycle 7, compliance testing
showed NKSP performed poorly in notifying providers of STAT laboratory results and
notifying patients of pathology and diagnostic results. Additional details can be found in
the Diagnostic Services and Provider Performance indicators.
Urgent and Emergent Records
OIG clinicians reviewed 26 emergency care events and found both NKSP nurses and
providers documented these events excellently. Case reviewers did not identify any
documentation deficiencies.
Scanning Performance
NKSP performed well in scanning. Compliance testing showed medical records were
properly scanned, labelled, and included in the correct patients’ files (MIT 4.004, 91.7%).
The OIG clinicians identified three deficiencies related to mislabeled or misfiled medical
documents and four documents that were not scanned timely. None of these deficiencies
were clinically significant. 34
OIG clinicians found nine deficiencies for illegible nursing signatures on several health
care services request forms, which hindered identifying which nurse made each triage
decision.35 These signatures should have been identified before scanning.
Continuity of Care
OIG clinicians identified a significant deficiency in which the management of health
information affected the continuity of care:
• In case 32, a new patient, who identified as transgender, arrived at
the reception center with incomplete medical records. However, staff
did not request the previous records needed to complete the patient’s
33 Deficiencies occurred in cases 15, 16, 18, and 54.
34 Deficiencies occurred in cases 2, 15, 18, and 54.
35 Deficiencies occurred in cases 23, 35, 39, 42, 43, 47, 48, and 50.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 37
medical history. Therefore, they did not continue the patient’s
transgender care timely.
Clinician On-Site Inspection
We discussed health information management processes with NKSP health information
management (HIM) supervisors, office technicians, ancillary staff, diagnostic staff,
nurses, and providers. HIM staff said they were fully staffed during the review period.
They did not identify any significant obstacles to completing their mission including no
significant COVID-19 impact.
HIM staff had access to one local hospital system’s electronic medical records, which
expedited receipt of those records. However, they did not have direct access to any
medical records systems—electronic or otherwise—belonging to the county jails from
which some 300 to 400 incarcerated people per week were transported to NKSP. NKSP
staff relied on paper documentation provided upon transfer for new patients arriving
from county facilities. Medical leadership reported county jail transfer records were often
unreliable and incomplete. HIM management stated the reception center nurses were
responsible for reviewing the transfer documentation and, if it appeared incomplete, they
would attempt to obtain additional records. HIM staff then would collect those paper
records reviewed in reception and scan them in the next business day. In emergent
situations, HIM staff would obtain and scan the records as quickly as necessary.
Leadership reported the on-site specialty nurses obtained the on-site specialty reports,
forwarded them to providers for hardcopy endorsement, then sent them to HIM for
scanning. HIM staff scanned the documents then forwarded the electronic versions for
provider endorsement in the EHRS. Health record technicians monitored this process
and sent follow up messages to the providers and leadership if specialty reports were not
endorsed timely.
In our case reviews, we found many incomplete or missing patient results notification
letters. HIM staff stated they do not train the providers on the requirements of these
letters or monitor completion. They believe the CME and the chief physician and surgeon
(CP&S) manage this process. This is discussed further in the Provider Performance and
Diagnostic Services indicators.
HIM supervisors stated the medical schedulers were responsible for scanning health care
services request forms and ensuring nurses’ signatures were legible on the scanned
versions. The supervisors told us staff would receive training to rectify this problem.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 38
Compliance Score Results
Table 8. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s electronic
20 0 10 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
25 5 15 83.3%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 17 3 5 85.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
22 2 0 91.7%
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: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 39
Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
2 8 0 20.0%
staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
10 0 0 100%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
2 8 0 20.0%
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 15 0 0 100%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 12 3 0 80.0%
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: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 40
Recommendations
We offer no specific recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 41
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 (55.5%)
Overall, NKSP performed poorly with health care environment. In this cycle, multiple
aspects of NKSP’s health care environment were poor: medical supply storage areas
inside of the clinics either contained expired medical supplies or medical supplies stored
directly on the floor; several areas of the examination rooms were unsanitary; emergency
medical response bag (EMRB) logs were missing staff verification or inventory was not
performed; several clinics did not meet the requirements for essential core medical
equipment and supplies; and staff did not regularly sanitize their hands before examining
patients. Based on the overall compliance score result, the OIG rated the compliance
component of this indicator inadequate.
Compliance Testing Results
Patient Waiting Areas
We inspected only indoor waiting areas as
NKSP had no outdoor waiting areas.
Health care and custody staff reported
existing waiting areas contained
sufficient seating capacity. Depending on
the population, patients were either
placed in the clinic waiting area or held in
individual treatment modules (see Photo
1). During our inspection, we did not
observe overcrowding in any of the
clinics’ indoor waiting areas.
Photo 1. Indoor waiting area with individual
treatment modules (photographed on 7-5-23).
.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 42
Clinic Environment
Nine of 11 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,
81.8%). In one clinic, the vital signs check station
was set up in the clinic hallway, and in the other
clinic, the triage stations were within close
proximity to each other. Both setups hindered
auditory privacy.
Of the 11 clinics we observed, seven contained
appropriate space, configuration, supplies, and
equipment to allow clinicians to perform proper
clinical examinations (MIT 5.110, 63.6%). In the
remaining four clinics, we observed one or more of
the following deficiencies: examination room was
cluttered (see Photo 2); examination room lacked
visual privacy for conducting clinical examinations;
clinics had unsecured confidential medical records;
the examination room’s wall mounted oto-
ophthalmoscope did not allow clinicians to
examine the patient while lying on the examination
table; examination chair was torn; and the clinic
lacked auditory privacy during clinical encounters Photo 2. Cluttered examination room
(see Photo 3, below). (photographed on 7-6-23).
Photo 3. The clinic lacked auditory privacy during clinical encounters
(photographed on 7-6-23).
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 43
Clinic Supplies
Only two of the 11 clinics
followed adequate medical
supply storage and
management protocols (MIT
5.107, 18.2%). We found one
or more of the following
deficiencies in nine clinics:
expired medical supplies
(see Photo 4); unorganized
or unidentified medical
supplies; cleaning materials
or medications stored with
medical supplies; and
medical supplies directly
stored on the floor (see
Photo 5).
Photo 4. Expired medical supply dated April 11, 2023
(photographed on 7-5-23).
Photo 5. Medical supplies stored directly
on the floor (photographed on 7-5-23).
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 44
None of the 11 clinics met requirements for essential core medical equipment and
supplies (MIT 5.108, zero). All 11 clinics lacked medical supplies or had nonfunctional
equipment. The missing items included examination table paper, lubricating jelly, and a
nebulization unit. Several clinics contained a nonfunctional oto-ophthalmoscope. In
addition, staff had not completed the automated external defibrillator performance test
log documentation within the previous 30 days, and several clinic daily glucometer
quality control logs were either inaccurate or incomplete.
We examined EMRBs to determine whether they contained all essential items. We
checked whether staff inspected the bags daily and inventoried them monthly. Only six of
the 10 EMRBs passed our test (MIT 5.111, 60.0%). In nine EMRBs we found one or more
of the following deficiencies: staff failed to ensure the EMRB’s compartments were sealed
and intact; staff had not inventoried the EMRBs when the seal tags were replaced;
EMRBs contained compromised medical supplies; or staff had not checked whether the
EMRB oxygen tank was properly pressurized every shift.
In addition to the above findings, our compliance inspectors found the following in the
clinics or examination rooms when they conducted their on-site inspection:
• Staff in Facility B had prefilled the clinic’s tool control inventory
report a day early (see Photo 6).
Photo 6. Staff prefilled the clinic’s tool control inventory report one day early (photographed on 7-6-23).
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 45
Medical Supply Management
Staff proficiently stored clinic medical supplies in the medical supply storage areas
outside the clinics (e.g., warehouse, Conex containers, etc.) (MIT 5.106, 100%). According
to the chief executive officer (CEO), the institution 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 five of 11 clinics (MIT 5.101, 45.5%).
In seven clinics, we found one or more of the following deficiencies: the cleaning logs
were not maintained; the clinic’s sink, cabinet under the sink, examination room floor,
stretcher (see Photo 7), patient restroom, and staff restroom were unsanitary; an insect
was in a drawer (see Photo 8); and a used glove was improperly disposed of in the shred
bin.
Photo 7. Dusty stretcher
(photographed on 7-6-23).
Photo 8. An insect found in a clinic drawer
(photographed on 7-7-23).
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 46
Staff in seven of 11 clinics (MIT 5.102, 63.6%) properly sterilized or disinfected medical
equipment. For three clinics, staff did not mention disinfecting the exam table as part of
their daily start-up protocol. For one clinic, the staff did not remove and replace the
examination table paper after each patient encounter.
We found operating sinks and hand hygiene supplies in the examination rooms in four of
11 clinics (MIT 5.103, 36.7%). In seven clinics, the patient restroom lacked antiseptic soap
and disposable hand towels.
We observed patient encounters in six applicable clinics. In three clinics, clinicians did
not wash their hands before examining their patients (MIT 5.104, 50.0%).
Health care staff in 10 of 11 clinics followed proper protocols to mitigate exposure to
bloodborne pathogens and contaminated waste (MIT 5.105, 90.9%). In one clinic, we
found a sharps container was overfilled, and biohazardous waste was not stored in the
clinic’s secured and labeled area.
Physical Infrastructure
At the time of our medical inspection, the institution reported the Health Care Facility
Improvement Program (HCFIP) project had ongoing construction to renovate the
pharmacy. The institution estimated the projects would be completed by the end of July
2023. In addition, the institution reported a construction delay for the pharmacy
renovation due to code issues pending fire marshal approval.
Despite the pharmacy renovation delay, the CEO did not believe it negatively impacted
the institution’s current ability to provide good patient care (MIT 5.999).
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Cycle 7, North Kern State Prison | 47
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,
5 6 0 45.5%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 7 4 0 63.6%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
4 7 0 36.4%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
3 3 5 50.0%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
10 1 0 90.9%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 1 0 0 100%
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
2 9 0 18.2%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
0 11 0 0
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
9 2 0 81.8%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
7 4 0 63.6%
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 6 4 1 60.0%
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): 55.5%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, North Kern State Prison | 48
Recommendations
• Medical leadership should analyze the root cause(s) of staff not
following all required universal hand hygiene precautions and should
implement necessary remedial measures.
• Executive leadership should analyze the root cause(s) of staff not
following equipment and medical supply management protocols and
should implement necessary remedial measures.
• Nursing leadership should determine the root cause(s) of staff not
ensuring the EMRBs are regularly inventoried and sealed, and of
staff failing to properly complete the monthly logs and should
implement necessary remedial measures.
• Executive leadership should determine the root cause(s) of unclean
clinics, medical storage rooms, and restrooms and should implement
necessary remedial measures.
Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7, North Kern State Prison | 49
Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions.
For newly arrived patients, our inspectors assessed the quality of health care screenings
and the continuity of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, inspectors checked
whether staff reviewed patient medical records and determined the patient’s need for
medical holds. They also assessed whether staff transferred patients with their medical
equipment and gave correct medications before patients left. In addition, our inspectors
evaluated the performance of staff in communicating vital health transfer information,
such as preexisting health conditions, pending appointments, tests, and specialty
referrals. Inspectors also confirmed whether staff sent complete medication transfer
packages to receiving institutions. For patients who returned from off-site hospitals or
emergency rooms, inspectors reviewed whether staff appropriately implemented
recommended treatment plans, administered necessary medications, and scheduled
appropriate follow-up appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (87.1%)
NKSP’s case review performance for this indicator was satisfactory. Compared to Cycle 6,
our clinicians reviewed a similar number of events and deficiencies. NKSP’s nursing staff
showed significant improvement in thoroughly completing the initial health screening
forms compared to Cycle 6. However, OIG clinicians found opportunities for
improvement in documentation of vital signs and pending specialty service referrals for
transfer-out patients. NKSP performed very well both in providing follow-up
appointments within required time frames to patients returning from hospitalization and
emergency room encounters as well as in retrieving and scanning hospital records timely.
After reviewing all aspects, the OIG rated the case review component of this indicator
adequate.
Compared with Cycle 6, NKSP’s compliance performance greatly improved for this
indicator. While compliance testing resulted in low scores for medication continuity for
newly transferred patients, the institution performed excellently in completing the
assessment and disposition section of the screening process. The institution also showed
good performance in ensuring transfer packets for departing patients included the
required documents and medications and in completing initial health screening forms for
newly arrived patients. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator proficient.
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Cycle 7, North Kern State Prison | 50
Case Review and Compliance Testing Results
We reviewed 25 events in 15 cases in which patients transferred into or out of the
institution or returned from an off-site hospital or emergency room. We identified 15
deficiencies, two of which were significant.36
Transfers In
OIG clinicians reviewed eight events in four cases in which patients transferred into the
facility from other institutions.37 The OIG clinicians found nurses evaluated patients
appropriately, provided appropriate interventions, and requested provider appointments
within required time frames in all cases reviewed.
Compliance testing showed nurses performed satisfactorily in completing the initial
health screening forms thoroughly (MIT 6.001, 84.0%) and always completed the
assessment and disposition sections of the initial health screening form (MIT 6.002,
100%). Compliance testing showed providers generally evaluated transfer-in patients
within the required time frame (MIT 1.002, 83.3%).
Compliance testing revealed NKSP needed improvement in providing timely medications
for transfer-in patients (MIT 6.003, 64.3%). The compliance team found NKSP performed
poorly with medication continuity for patients laying over at the institution (MIT 7.006,
30.0%). However, patients who transferred from one housing unit to another frequently
received medications without interruption (MIT 7.005, 80.0%). The case review clinicians
identified one deficiency in medication continuity that was not significant. Please refer to
the Medication Management indicator for further details.
Compliance testing showed patients who transferred into NKSP with preapproved
specialty service appointments were usually scheduled timely (MIT 14.001, 80.0%). Please
refer to the Specialty Services indicator for further details.
Transfers Out
NKSP’s performance in the transfer-out process was fair. OIG clinicians reviewed five
transfer-out cases and found five deficiencies, none of which were significant.38 In
compliance testing, nurses performed excellently with ensuring transfer packages
included required medications and documents (MIT 6.101, 100%). However, our clinicians
identified missing documentation and vital signs as described in the following cases:
• In cases 22 and 30, prior to the patients’ transfer, nurses did not
obtain a complete set of vital signs.
• In cases 2, 29, 30 and 31, nurses did not accurately complete the
interfacility documentation to include all pending specialist
appointments, such as a colonoscopy, EMG, TTE, and GI specialty
36 Deficiencies occurred in cases 2, 19, 22, 24, 25, 27–31, and 55. Significant deficiencies occurred in cases 27 and
55.
37 Transfer-in deficiencies occurred in cases 25, 27, and 28. A significant deficiency occurred in case 27.
38 Transfer-out deficiencies occurred in cases 2, 22, and 29–31. No significant deficiencies occurred.
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consultation.39 Fortunately, the receiving institutions reconciled the
pending specialty appointments.
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at high risk for
lapses in care quality. These patients typically have 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.
NKSP performed very well in providing follow-up appointments within required time
frames to patients returning from hospitalizations and emergency room encounters (MIT
1.007, 92.0%). NKSP’s performance was good in retrieving and scanning hospital records
(MIT 4.003, 85.0%). Compliance testing showed providers always reviewed and endorsed
documents timely (MIT 4.005, 100%). Please refer to the Health Information
Management indicator for further details.
The OIG clinicians reviewed 10 events that occurred in nine cases for patients who were
treated at a community hospital.40 We identified seven deficiencies, one of which was
significant.41
• In case 55, the patient with a bone infection returned from the
hospital after the hospital staff was unable to reestablish the PICC
line.42 The hospital recommended the patient return the following
day. In the interim, the hospital placed a right-arm peripheral IV to
administer antibiotics. The patient was returned to the CTC housing
unit. The nurses did not assess or document the left-arm PICC line
site or document the antibiotic should only be administered through
the new peripheral IV in the right arm per the hospital
recommendations. Fortunately, the patient received the antibiotic as
ordered.
Compliance testing showed NKSP performed poorly in medication continuity for
patients discharging from the hospital to the institution (MIT 7.003, 44.0%). Case
reviewers identified one medication deficiency, which was not significant.43 Please refer
to the Medication Management indicator for further details.
Patients almost always received timely provider follow-up appointments (MIT 1.007,
92.0%). Similarly, case review found no deficiencies for delays in provider follow-up
appointments. Providers always reviewed hospital discharge documentation within the
required time frame (MIT 4.005, 100%). Hospital or emergency room summary reports
39 Electromyography (EMG) measures muscle response or electrical activity in response to a nerve’s stimulation
to the muscle. Transthoracic echocardiogram (TTE) is an ultrasound of the heart. Gastrointestinal (GI) specialist
evaluates the digestive system.
40 Hospitalization events occurred in cases 1, 2, 19–24, and 55.
41 Deficiencies occurred in cases 2, 19, 22, 24, and 55. A significant deficiency occurred in case 55.
42 PICC line is a peripherally inserted central catheter used to administer medications or obtain blood tests.
43 Deficiencies occurred in case 2.
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were generally scanned into EHRS and made available within required time frames (MIT
4.003, 85.0%). Please refer to the Health Information Management indicator for further
details.
Clinician On-Site Inspection
During the OIG clinician on-site inspection, the reception center (RC) RNs conducted all
RC intake transfers and intake screening for patients arriving from another institution.
The RC RNs were assigned to the morning and evening shifts. The receiving and release
(R&R) RN performed the transfer-out process. One R&R RN is assigned on each morning
and evening shift. On the graveyard shifts, two R&R RNs and one LVN are assigned.
NKSP had between 60 to 120 transfer-out patients per day. The nurse reported, three
months prior to the clinician on-site inspection, they had added one LVN to R&R for the
early morning medication administration, and this new process had helped the RNs
tremendously with the large number of patients requiring medications prior to transfer.
The nurses reported one office technician was assigned to assist the nurses with the
transfer packets. In the R&R, one medication cart had LCC medications so the nurses
could administer medications timely during patient arrivals and departures.44 The R&R
had no Omnicell, so if additional medication was needed, they would obtain medications
from the TTA Omnicell, which was in close proximity.45
The TTA, R&R, and specialty areas were supervised by the same SRN. OIG clinicians
identified a best practice at NKSP wherein this SRN performed daily huddles with the
specialty team to ensure all new transfers or patients returning from the hospital had
appropriate follow-up appointments and medications. In addition, this SRN ensured
specialty referrals were timely reconciled.
44 The licensed correctional clinic (LCC) stock are stock medications provided by the pharmacy for the medical
staff to administer that are not patient specific.
45 An Omnicell is an automated medication dispensing machine.
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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 21 4 0 84.0%
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 21 0 4 100%
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 9 5 11 64.3%
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 10 0 0 100%
required documents? (6.101)
Overall percentage (MIT 6): 87.1%
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 20 4 1 83.3%
patient seen by the clinician within the required time frame? (1.002)
Upon the patient’s discharge from the community hospital: Did the patient
receive a follow-up appointment with a primary care provider within the 23 2 0 92.0%
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? 17 3 5 85.0%
(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 11 14 0 44.0%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
20 5 0 80.0%
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
7 4 0 63.6%
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
We offer no specific recommendations for this indicator.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in
administering prescription medications on time and without interruption. The inspectors
examined this process from the time a provider prescribed medication until the nurse
administered the medication to the patient. When rating this indicator, the OIG strongly
considered the compliance test results, which tested medication processes to a much
greater degree than case review testing. 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 (61.8%)
Case review found NKSP performed well in providing medications timely for transfer-
out, transfer-in, reception center, hospital discharge, and specialized medical housing
patients. However, NKSP needed improvement in medication continuity for chronic care
medications. Overall, the OIG rated the case review component of this indicator
adequate.
Compliance testing showed NKSP had a mixed performance for this indicator. The
institution’s pharmacy performed exceptionally in employing general security and storing
medications in its main pharmacy. Compliance testing showed NKSP staff were
proficient in medication continuity for transfer-out patients, and staff performed well in
medication continuity for patients newly arrived to the reception center and patients
transferring from one housing unit to another. Conversely, the institution still requires
great improvement in timely providing chronic care medications, newly prescribed
medication orders, hospital discharge medications, and medications for patients
temporarily housed at NKSP. Based on the overall compliance score result, the OIG rated
the compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 120 events in 29 cases related to medications and found 16 medication
deficiencies, six of which were significant.46
New Medication Prescriptions
Compliance testing showed new medications were available or administered without
delay a majority of the time (MIT 7.002, 75.0%). Compliance testing showed five samples
of medications that either were not made available or were delivered to the patient up to
46 Deficiencies occurred in cases 1, 2, 9, 12–14, 17, 18, 23, 25, 28, 34, and 55. Significant deficiencies occurred in
cases 12–14, 17, and 23.
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two days late. Our clinicians found four deficiencies related to new medications not being
timely administered, one of which was significant.47 Two examples follow:
• In case 1, the patient underwent an off-site surgical procedure and
an antibiotic, Keflex, was ordered; however, the patient received the
keep-on-person (KOP) antibiotic one day late.
• In case 23, the patient with a nasal skin infection received his newly
ordered KOP amoxicillin medication two days late.
Chronic Medication Continuity
NKSP needed improvement in ensuring medication continuity for patients with chronic
conditions. Compliance testing showed patients intermittently received their chronic
care medications within required time frames (MIT 7.001, 52.2%). Compliance testing
showed patients on medications for high blood pressure, cholesterol, or asthma received
medication one day late or not at all. In addition, compliance testing revealed a patient
refused insulin as scheduled multiple times; however, we found no documentation of
counseling from the patient care team for refusing three or more consecutive days of
insulin. In case review, our clinicians found patients did not receive their chronic care
medications timely or did not receive them at all.48
• In case 12, during the month of January 2023, the diabetic patient did
not receive the KOP diabetic medications Jardiance and metformin.
The patient received the KOP diabetic medications in February
2023, one month later.
• In case 13, during the month of January 2023, the diabetic patient did
not receive the scheduled monthly KOP metformin. The KOP
metformin was given in December 2022 and the next dose was given
February 2023, almost two months later.
• In case 14, during the month of December 2022, the patient did not
receive the KOP medications metformin and atorvastatin
(cholesterol medication).
• In case 17, the patient was scheduled to receive the KOP lisinopril to
treat high blood pressure. The patient did not receive the medication
until three weeks later.
• In case 23, in the month of February 2023, the patient did not receive
KOP medications for high blood pressure: amlodipine, furosemide,
and hydralazine. The patient did not receive all the medications until
they were nurse administered in March 2023, more than two months
after the last administration of the KOP medication.
47 New medication not received timely occurred in cases 1, 9, 18, and 23. A significant deficiency occurred in
case 23.
48 Chronic care medications not received timely occurred in cases 12–14, 17, 23, and 25. Significant deficiencies
occurred in cases 12–14, 17, and 23.
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Hospital Discharge Medications
Compliance testing showed NKSP performed poorly in ensuring patients received needed
medications when they returned from an off-site hospital or emergency room (MIT 7.003,
44.0%). Testing similarly showed patients returning from the hospital did not receive
their high blood pressure, antibiotic, cholesterol, diabetes, or seizure medications timely.
In contrast, our clinicians found patients almost always received hospital discharge
medications timely.49
Transfer Medications
Compliance testing showed NKSP needed improvement in ensuring medication
continuity for patients transferring into the institution (MIT 6.003, 64.3%). Compliance
testing found a patient on high cholesterol medication received the medication 13 days
late. Compliance testing also showed staff documented patients’ refusals or no show/no
barriers in the MAR; however, we found no documentation of the reason for the refusal
or no show/no barriers. In contrast, OIG clinicians found the majority of the patients
reviewed received their medications within the required time frame.
OIG clinicians and compliance testing found patients who transferred out of NKSP to
another institution had all their transfer medications (MIT 6.101, 100%). Compliance
testing showed patients who transferred from one housing unit to another generally
received their medications timely (MIT 7.005, 80.0%). However, NKSP performed poorly
in medication continuity for patients laying over at the institution (MIT 7.006, 30.0%).
Reception Center Medications
OIG clinicians and compliance testing found NKSP performed very well in ensuring
patients arriving from the county jail received medications timely (MIT 7.004, 90.0%).
Specialized Medical Housing Medications
Medication continuity performance for patients admitted to the CTC was mixed.
Compliance testing showed few patients admitted to the CTC received their medications
timely (MIT 13.003, 40.0%). In contrast, our clinicians found only one deficiency related to
medication management, which was not significant.50
Medication Administration
NKSP performed very well in administering tuberculosis (TB) medications (MIT 9.001,
88.0%). However, nurses performed poorly in monitoring patients’ prescribed TB
medications (MIT 9.002, 28.0%). OIG clinicians did not identify any cases with lapses in
administering TB medication.
Clinician On-Site Inspection
At the on-site inspection, the clinicians met with the pharmacist and nursing leadership
to discuss case findings. During our discussion, the pharmacist informed us the
49 Hospital discharge medication deficiency occurred in case 2.
50 CTC medication deficiency occurred in case 55.
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pharmacy department moved into their newly renovated location on Labor Day. Plans for
the new space, drafted in 2009, originally intended to allow all pharmacy staff to work
alongside the pharmacist. Unfortunately, due to the increase in pharmacy staff since
2009, the pharmacy department’s workspace limitations did not improve.
The CEO indicated the pharmacy was short staffed between November 2022 and April
2023, which caused challenges with meeting the medication demands. These challenges
were further exacerbated because NKSP is a reception center institution and has a high
volume of patients in the integrated substance use disorder treatment program. They
continued to provide the medications by offering overtime to the pharmacy staff.
OIG clinicians also toured the medication areas and interviewed medication nurses. We
found the nurses were knowledgeable about the medication process. The medication
nurses attended clinic huddles and notified the providers of expiring medications and
other medication-related concerns.
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in six of nine
applicable clinic and medication line locations (MIT 7.101, 66.7%). In two locations,
narcotic medications were not properly and securely stored as required by CCHCS policy.
In the remaining clinic, the nursing supervisor did not accurately describe the narcotic
medication discrepancy reporting process.
NKSP appropriately stored and secured nonnarcotic medications in five of 11 clinic and
medication line locations (MIT 7.102, 45.5%). In three locations, the medication area
either lacked a clearly labeled designated area for refrigerated medication returns to the
pharmacy, or the designated bin for returns to the pharmacy was unsanitary. In two
locations, nurses did not maintain unissued medication in its original labeled packaging.
In one location, the treatment cart log was missing daily security check entries.
Staff kept medications protected from physical, chemical, and temperature
contamination in four of the 11 clinic and medication line locations (MIT 7.103, 36.4%). In
seven locations, we found one or more of the following deficiencies: staff did not
consistently record the room temperature; staff did not store internal and external
medications separately; staff stored medications with disinfectants; staff stored
medications directly on the floor; and the medication refrigerator was unsanitary.
Staff successfully stored valid, unexpired medications in eight of the 11 applicable
medication line locations (MIT 7.104, 72.7%). In three locations, nurses did not label
multi-use medications as required by CCHCS policy. In one of the three locations, we
found expired medication vials.
Nurses exercised proper hand hygiene and contamination control protocols in one of
seven applicable locations (MIT 7.105, 14.3%). In six locations, some nurses neglected to
wash or sanitize their hands before preparing and administering medications, before
donning gloves, or before each subsequent regloving. In two of the six locations, the
medication nurses did not change gloves when the integrity of the gloves was
compromised.
Staff in six of seven applicable medication preparation and administration areas had
appropriate administrative controls and protocols (MIT 7.106, 85.7%). In one location,
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medication nurses did not describe the process they followed when reconciling newly
received medication and the medication administration record (MAR) against 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 the required time
frames; medication nurses did not always verify patients’ identification using a secondary
identifier; medication nurses did not consistently observe patients while they swallowed
direct observation therapy medications; and medication nurses did not follow CCHCS
care guide when administering Suboxone medication.
Pharmacy Protocols
NKSP always followed general security, organization, and cleanliness management
protocols for nonrefrigerated and refrigerated medications stored in its pharmacy (MITs
7.108, 7.109, and 7.110, 100%).
The pharmacist-in-charge (PIC) did not thoroughly review monthly inventories of
controlled substances in the institution’s clinic and medication storage locations.
Specifically, the nurse present at the time of the medication area inspection did not
correctly complete the medication area inspection checklist (CDCR Form 7477) in one
location. This error resulted in a score of zero for this test (MIT 7.111).
We examined 12 medication error reports. The PIC timely and correctly processed 11 of
these 12 reports (MIT 7.112, 91.7%). The PIC did not provide a pharmacy error follow-up
review form for one medication error.
Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors
also followed up on any significant medication errors found during compliance testing.
We did not score this test; we provide these results for informational purposes only. At
NKSP, the OIG did not find any applicable medication errors (MIT 7.998).
The OIG interviewed patients in restricted housing units to determine whether they had
immediate access to their prescribed asthma rescue inhalers or nitroglycerin
medications. All nine applicable patients interviewed indicated they had access to their
rescue medications (MIT 7.999).
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Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
12 11 2 52.2%
or did the institution follow departmental policy for refusals or no‑shows? (7.001)
Did health care staff administer, make available, or deliver new order prescription
18 6 1 75.0%
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 11 14 0 44.0%
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 9 1 10 90.0%
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
20 5 0 80.0%
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 6 3 3 66.7%
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 5 6 1 45.5%
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 4 7 1 36.4%
the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution safely store nonnarcotic medications that have yet to expire in the 8 3 1 72.7%
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 1 6 5 14.3%
medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 6 1 5 85.7%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 2 5 5 28.6%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization, and
1 0 0 100%
cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
1 0 0 100%
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
1 0 0 100%
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
0 1 0 0
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting protocols?
11 1 0 91.7%
(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): 61.8%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Specialized Services
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 9 5 11 64.3%
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 10 0 0 100%
required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
22 3 0 88.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 7 18 0 28.0%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 4 6 0 40.0%
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• The institution should develop and implement measures to ensure
staff timely make available and administer medications to patients
and document the medication administration record (MAR)
summaries, as described in CCHCS policy and procedures.
• Nursing leadership should determine the challenges for nursing staff
in documenting patient refusals in the MAR, as described in CCHCS
policy and procedures, and 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 Inadequate (74.5%)
NKSP showed a mixed performance in providing preventive services. Staff performed
well in administering medications to patients who were prescribed TB medications,
screening patients annually for TB, offering patients an influenza vaccine for the most
recent influenza season, and offering colorectal cancer screening for patients from ages
45 through 75. However, NKSP performed poorly in monitoring patients taking
prescribed TB medications, needed improvement in offering required immunizations to
chronic care patients, and did not always timely transfer patients at the highest risk for
coccidioidomycosis (Valley Fever). Based on the overall compliance score result, the OIG
rated the compliance component of this indicator inadequate.
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Compliance Score Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
22 3 0 88.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 7 18 0 28.0%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
25 0 0 100%
(9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
21 4 0 84.0%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care
9 8 8 52.9%
patients? (9.008)
Are patients at the highest risk of coccidioidomycosis (Valley Fever)
13 6 0 68.4%
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 74.5%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should develop and implement measures to ensure
nursing staff consistently perform patient monitoring as described in
CCHCS Care Guides, and nursing staff completely address TB signs and
symptoms in their patient monitoring.
• Medical leadership should determine the challenges to timely
providing immunizations to chronic care patients and implement
remedial measures as appropriate.
• Medical leadership should develop strategies to ensure patients at
the highest risk of coccidioidomycosis (Valley Fever) are transferred
in a timely manner and implement remedial measures as appropriate.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care delivered by the
institution’s nurses, including registered nurses (RN), licensed vocational nurses (LVN),
psychiatric technicians (PT), certified nursing assistants (CNA), and medical assistants
(MA). Our clinicians evaluated nurses’ performance in making timely and appropriate
assessments and interventions. We also evaluated the institution’s nurses’ documentation
for accuracy and thoroughness. Clinicians reviewed nursing performance across many
clinical settings and processes, including sick call, outpatient care, care coordination and
management, emergency services, specialized medical housing, hospitalizations,
transfers, specialty services, and medication management. The OIG assessed nursing care
through case review only and performed no compliance testing for this indicator.
When summarizing nursing performance, our clinicians understand 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
NKSP nurses generally delivered good care, documented appropriately most of the time,
and did well with providing timely face-to-face appointments. However, OIG clinicians
found opportunities for improvement in nursing assessments, which did not increase risk
of harm to patients. The OIG rated this indicator adequate.
Case Review Results
We reviewed 168 nursing encounters in 48 cases. Of the nursing encounters we reviewed,
67 occurred in the outpatient setting. We identified 85 nursing performance deficiencies,
12 of which were significant.51
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. A comprehensive assessment allows nurses to gather essential information
about their patients and to develop appropriate interventions.
Nurses frequently provided timely and appropriate nursing care. Our clinicians identified
39 sick call events in 32 cases. In those events, our clinicians identified 31 outpatient
51 Deficiencies occurred in case 1, 2, 4, 8, 9, 15, 17–24, 29–31, 33, 34, 40, 44, 46–51, and 53–55. Significant
deficiencies occurred in cases 1, 4, 9, 19, 23, 24, 50, and 55.
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nursing deficiencies, three of which were considered significant.52 Of the 32 deficiencies,
17 were sick call deficiencies, one of which was significant.53 These deficiencies occurred
when the nursing staff did not always perform complete assessments. Examples of
incomplete assessments are as follows:
• Our clinicians found a pattern of NKSP nursing staff not performing
a set of vital signs or missing components to include a full set of vital
signs in cases 1, 9, 17, 23, 46, 47, and 48.
• In case 9, the patient was in COVID-19 isolation during the review
period. The patient had flu-like symptoms with fever, pain, and an
elevated heart rate. However, the nursing staff frequently did not
complete a full set of vital signs to include blood pressure readings
and frequently did not address whether previous symptoms were
worsening or resolving. Secondly, on several occasions, nursing staff
did not perform COVID-19 isolation rounding twice per day as
ordered. Lastly, the patient’s oxygen saturation had decreased to 94%
on three occasions; however, the nurses did not reassess the oxygen
saturation, auscultate lung sounds, or obtain a blood pressure
reading and did not consult a provider.
• In case 49, the RN evaluated the patient for an infection to the right
arm. However, the sick call nurse did not assess right arm range of
motion. In addition, the nurse did not document the measurements
of the infection and did not document if the patient was compliant
with the KOP doxycycline medication that was provided the day
prior for the arm infection.
• In case 50, nursing staff triaged a sick call request for a hospital
checkup due to pain that had caused loss of feeling to the lower
body, trouble sleeping, and a report of falling once in the shower.
The patient was not evaluated the same day of the sick call triage for
the report of falling in the shower. The sick call RN evaluated the
patient the next day and documented the patient had chronic lower
back pain with spinal stenosis and had a pending back surgery
appointment. However, the nurse did not assess extremity strength,
sensation, and range of motion. In addition, the nurse did not obtain
information regarding the fall in the shower to include the date and
time of the incident, how the patient landed, if it was witnessed, and
whether the patient sustained any injuries at the time of the fall.
52 Deficiencies occurred in cases 1, 2, 8, 9, 15, 17–19, 22–24, 40, 44, and 46–51. Significant deficiencies occurred
in cases 9 and 50.
53 Sick call deficiencies occurred in cases 1, 2, 8, 17, 19, 23, 24, 40, 44, and 46–51. A significant deficiency
occurred in case 50.
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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. NKSP nursing staff frequently documented care appropriately.
However, emergency services, transfers, and specialized medical housing showed room
for improvement in documentation. Please refer to the Emergency Services, Transfers,
and Specialized Medical Housing indicators for further details.
Case Management
Care managers evaluated patients with chronic conditions such as diabetes,
hypertension, hepatitis C, and asthma. OIG clinicians reviewed two cases in which
patients were evaluated by a care manager and identified one deficiency, which was not
significant.54 During the clinician on-site inspection, we were informed the care
managers evaluated approximately 12 patients per day.
Wound Care
We reviewed three cases in which wound care was provided to the patients.55 In two
cases, the patients were in the CTC with a PICC line.56 The clinicians identified
opportunities for improvement in assessing the PICC line care as well as dressing
changes. Please refer to the Specialized Medical Housing indicator for further details.
At the clinician on-site inspection, nursing staff informed us the licensed vocational
nurse and psychiatric technicians performed wound care, which included documenting
the measurement of the wound, documenting the wound drainage color, and noting any
infection. In addition, they were to document if the wound was improving and to check
whether the dressing was appropriate or needed reassessment with the RN or primary
care physician (PCP).
Emergency Services
We reviewed 16 cases with 26 urgent or emergent events. We found 18 nursing
performance deficiencies, six of which were significant.57 Nurses generally responded
promptly to emergent events. However, we identified a pattern with delays in notifying
emergency medical services and with the CME or CNE not conducting clinical reviews of
the unscheduled transfers. In addition, the nurses did not always perform an initial
thorough assessment or reassess patients while waiting for the ambulance transfer to the
hospital. Please refer to the Emergency Services indicator for further details.
54 Patients evaluated by the care manager occurred in cases 3 and 9.
55 Wound care occurred in cases 22, 54, and 55.
56 PICC is a peripherally inserted central catheter, which provides intravenous access to administer fluids and
medication.
57 Nursing performance deficiencies occurred in cases 1, 2, 4, 8, 9, 19–21, 23, and 24. Significant deficiencies
occurred in cases 1, 4, 9, 19, 23, and 24.
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Hospital Returns
We reviewed 10 events in nine cases that involved returns from off-site hospitals or
emergency rooms. We identified four nursing performance deficiencies, one of which was
significant.58 Please refer to the Transfers indicator for further details.
Transfers
We reviewed 15 cases that involved transfer-in and transfer-out processes. The nurses
evaluated patients appropriately and initiated provider appointments within appropriate
time frames. However, OIG clinicians found opportunities for improvement in
documenting vital signs as well as pending specialty service referrals for transfer-out
patients. Please refer to the Transfers indicator for further details.
Reception Center
We reviewed eight reception center cases with 27 events. The clinicians identified five
nursing performance deficiencies, none of which were significant. OIG clinicians found
nurses generally completed the initial health screening forms and performed thorough
assessments. Please refer to the Reception Center indicator for further details.
Specialized Medical Housing
We reviewed four CTC cases with a total of 88 events that included 32 provider events
and 20 nursing events. We identified 33 deficiencies, four of which were significant.59 The
clinicians found 17 of the deficiencies related to nursing performance, two of which were
significant.60 The clinicians found opportunities for improvement in nursing
assessments, documentation, and PICC line care. Please refer to the Specialized Medical
Housing indicator for further details.
Specialty Services
We reviewed 24 events in 10 cases in which nurses evaluated patients after returning
from off-site specialist appointments or procedures. The clinicians identified five
deficiencies, none of which were significant.61 The nursing staff provided good
assessments, reviewed specialists’ findings and recommendations, and communicated
those results to the provider. The clinicians found opportunities for improvement in
nursing documentation in four cases; however, it did not affect overall patient care.
58 Nursing performance deficiencies occurred in cases 2, 19, 22, and 55. A significant deficiency occurred in case
55.
59 Deficiencies occurred in cases 24 and 53–55. Significant deficiencies occurred in cases 53 and 55.
60 Nursing performance deficiencies occurred in cases 24 and 53–55. Two significant deficiencies occurred in
case 55.
61 Deficiencies occurred in cases 17, 18, 20, and 53.
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Medication Management
OIG clinicians reviewed 120 events in 29 cases involving medication management. The
OIG clinicians and compliance testing had mixed reviews. Please refer to the Medication
Management indicator for further details.
Clinician On-Site Inspection
At the OIG clinician on-site inspection, our clinicians interviewed nurses in the TTA,
CTC, Reception Center, specialty services, outpatient clinics, and medication areas. We
attended well organized huddles in the clinics and the CTC and found staff were
knowledgeable and familiar with their patient population. The nurses reported both the
medication nurses and medication administration provided wound care, vaccines, and
NIDA screenings.62
The ISUDT SRN reported approximately 400 patients were in the ISUDT program and on
Suboxone. The SRN reported the challenges for patients in the ISUDT program were the
short-term stay, custody level, and limits on where patients who need methadone
treatment could transfer. Only eight institutions are set up for methadone delivery
(Substance Abuse Treatment Facility, California State Prison - Corcoran, Mule Creek
State Prison, Valley State Prison, Wasco State Prison, North Kern State Prison, San
Quentin Rehabilitation Center, and California Institution for Men).
NKSP C Yard had a population of 1,500 patients in a dorm setting that housed patients in
general population and sensitive needs yard (SNY) as well as housing northerners.
Nursing staff reported, normally, they have two primary RNs and two case manager RNs,
but filling one primary RN vacancy position had been difficult. As a result, one case
manager was frequently redirected to assist with sick call face-to-face (FTF)
appointments. The case managers evaluated approximately 15 patients per day. The RNs
would triage approximately 50 to 70 sick call requests per day and evaluate approximately
25 to 50 sick call FTF appointments a day. To help with the large volume, the case
manager RN would assist and volunteer to stay after hours. This yard had a minimal
backlog (three RN, one LVN) for the nursing staff at the time of our inspection, and all
the backlog patients were scheduled that day. In contrast, the providers had a large
backlog (159 requests). Newly arrived patients who were cleared after COVID-19
quarantine from B and D Yards were transferred to C Yard until they could transfer to
the main yard, which contributed to the backlog in C Yard. The SRN reported challenges
with patients being seen timely for their scheduled appointments in the clinic due to
patients in the sensitive needs yard or the patient’s gang affiliation, which required those
patients not be housed or grouped together. Therefore, some patients were not seen as
scheduled, and custody staff would work with medical staff the best they could. Staff also
reported the challenge that telemedicine MAT appointments with social workers were
time sensitive, which slowed the process for getting patients to the RN and provider
lines.
D Yard had a population of 580 patients and housed 16 patients in COVID-19 isolation.
We were informed the LVNs completed the isolation rounding, and if they found any
abnormalities, they would contact the RN or PCP. LVNs also completed the low risk
COVID scoring on the registry. This yard had two primary RNs and one care manager
62 National Institute on Drug Abuse (NIDA) is a screening tool utilized to identify substance use.
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RN. NKSP staff reported RNs triaged approximately 35 sick calls per day and had 15
patients on the RN line per day.
Clinic SRNs reported they conducted 10 sick call face-to-face (FTF) audits per month per
RN, and the testing was chosen randomly. In addition, SRNs reported they performed
spot audits of both the primary and case manager charting, and provided training as
needed. Staff reported, during huddles and population management meetings, they
discussed patient care and any issues with orders, interventions, or medications. They
also discussed if patients needed follow up care was needed and whether the care was
appropriately ordered.
We met with the CNE, who addressed our findings and acknowledged several
opportunities for improvements in nursing assessment, interventions, and
documentation.
The CNE reported the RN clinic in B and C Yards have the largest sick call lines, from 30
to 45 patients per day. The CNE reported challenges with scheduling appointments. The
large volume of appointments, approximately 250 bed moves per day, and patients
frequently transferring in and out of the institution contributed to the difficulty in
scheduling the patients timely. Even with the challenges the CNE reported, NKSP
performed well (at 90 percent) in providing RN FTF appointment triage in one day for
August 2023 in the Master Registry.
The CNE expressed challenges with implementing CCHCS programs and projects due to
the institution being a reception center institution, decrease in staffing, and staff not
staying more than three months. The CNE reported staff were leaving for higher
education, better jobs, and greater work-life balance.
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Recommendations
• Nursing leadership should determine the challenges that prevent
outpatient nurses from performing complete assessments and
implement remedial measures as indicated, such as training staff.
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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
OIG case review found provider performance was mixed. Providers generally completed
proper assessments and made sound medical decisions for their patients; however, we
found some deficiencies. Providers performed well reviewing medical records carefully.
Chronic care and continuity of provider care were good. Usually, providers gave
appropriate emergency care while at the institution; however, the mode of emergency
transport and associated times were sometimes inappropriate for patients’ medical
conditions. We identified a pattern of providers ordering specialty services for
inappropriate time frames. In addition, providers did not always document progress
notes, update patient medical record problem lists, or send complete patient test results
notification letters. Factoring all performance aspects, the OIG rated this indicator
adequate.
Case Review Results
OIG clinicians reviewed 102 medical provider encounters and identified 81 deficiencies,
16 of which were significant.63 We identified 28 deficiencies due to missing patient
results notification letters. In addition, our OIG physicians examined the quality of care
in 20 comprehensive case reviews. Of these 20 cases, we found 18 adequate and two
inadequate.64
Outpatient Assessment and Decision-making
Providers generally completed proper assessments and made sound medical decisions for
their patients. Being a reception center, we recognize the significant challenges
associated with the large volume of patients coming into and going out of the facility.
Most of the time, the providers took good histories, formulated differential diagnoses,
63 Deficiencies occurred in cases 1, 2, 8, 9–20, 22–25, and 53–55. Significant deficiencies occurred in cases 1, 8, 9,
16, 19, 20, 23, 25, 53, and 55.
64 We rated cases 9 and 25 inadequate.
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ordered appropriate tests, provided care with the correct diagnosis, and referred patients
to proper specialists when needed.
We identified 17 provider assessment and decision-making deficiencies, eight of which
were significant and led to the death of one patient.65 The following are examples:
• In case 1, the patient arrived from county jail with medical
complaints consistent with a heart attack. The TTA provider did not
order prophylactic nitroglycerin, which is standard care, despite
being aware of the patient’s history of a heart attack one month
prior. This increased the patient’s risk of injury and death.
• In case 9, an RN documented seeing a previously healthy patient
with fever, body aches, shortness of breath, hemoptysis (coughing up
blood), and chest pain with deep breathing. The provider was called
and ordered Tylenol, COVID-19 RNA testing, and COVID-19 point
of care testing. Within minutes, the same RN placed orders from a
different provider ordering COVID-19 isolation rounding and
contact precautions for 14 days. Neither provider ordered a provider
follow-up assessment to ensure the patient improved or the coughing
up blood was investigated. When the COVID tests returned negative,
indicating the patient’s symptoms were not from COVID-19, a
provider did not reassess the patient. Neither provider documented
the phone call from the nurse explaining the medical reasoning for
the orders or the intended plan of care.
• Later in case 9, nursing informed a provider this patient, who had
been in isolation for 13 days due to fever, chills, body aches,
hemoptysis, and shortness of breath, again had fever, a rapid heart
rate, chills, and a persistent cough. Despite this communication, no
orders were placed, a provider did not see the patient, and no
provider documentation was written. The ill patient was never
assessed by a provider and died nine days later. Additional nursing
deficiencies also contributed to the patient’s demise throughout this
case. The coroner determined the patient died of pneumonia.66 Had
the patient been appropriately evaluated and treated, his outcome
could have been different. The OIG considered this patient’s death to
be an adverse event.
Outpatient Review of Records
Providers usually reviewed medical records carefully. This is especially critical because
NKSP is a reception center for incoming patients. Collecting and documenting a
65Provider assessment and decision-making deficiencies occurred in cases 1, 2, 8, 9, 15, 23, 24, 34, and 53.
Significant deficiencies occurred in cases 1, 8, 9, and 23. We identified deficiencies that contributed to an
adverse event (death) in case 9.
66 Pneumonia is a generally treatable medical condition.
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patient’s outside medical data is critical to ensure adequate continuity of care. We
identified only three deficiencies, none of which were significant.67
Emergency Care
Providers usually managed patients in the TTA with urgent or emergent conditions
appropriately. However, we found providers may not have sent patients to the hospital by
the appropriate ambulance designation.68 Of the 10 emergency cases where the patient
required emergent transport, we identified two instances where the patients should have
been sent emergently but were sent urgently, which led to delays in care. Both
deficiencies were significant and are discussed further in the Emergency Services
indicator and Clinician On-Site Inspection area below.
Chronic Care
In most instances, providers appropriately managed patients’ chronic health conditions,
were familiar with their patients, and provided appropriate care. We identified five
deficiencies with quality of patient care, two of which were significant and are described
below: 69
• In case 8, the provider performed a new intake H&P on a patient
with a history of brain injury, intracranial shunt, and only one
kidney. The provider did not perform a complete baseline neurologic
exam, documented an inaccurate assessment of the cranial nerves,
did not order outside medical records to ensure accurate medical
history was obtained, and did not assess the patient’s remaining
kidney function.
• In case 23, the provider did not recognize the patient had critically
elevated blood pressure requiring immediate treatment. This placed
the patient at risk of possible stroke or heart injury.
Specialty Services
Providers usually reviewed high-priority specialty reports timely, but as discussed in the
Health Information Management indicator, compliance testing revealed medium- and
high-priority specialty report endorsements were sometimes delayed. Once specialty
reports were reviewed, however, providers usually acted upon the specialist’s
recommendations and referred patients for specialty consultations. Case review
identified a pattern of providers ordering referrals inappropriate priority time frames or
for incorrect locations of specialty services (e.g., ordered telemedicine provider but
required an on-site provider assessment). We found eight deficiencies, five of which were
significant. Examples of significant deficiencies include:70
67 Poor record review deficiencies occurred in cases 1, 53, and 55.
68 Emergency events requiring a higher level of care transport occurred in cases 1, 2, 19–24, and 55. Emergency
transport deficiencies occurred in cases 19 and 20; both were significant.
69 Chronic care deficiencies occurred in cases 8, 15, 23, 34, and 54. Significant deficiencies occurred in cases 8
and 23.
70 Deficiencies occurred in cases 1, 16, 25, 53, and 55. Significant deficiencies occurred in cases 16, 25, and 55.
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• In case 16, the patient’s prostate biopsy was positive for intermediate
risk prostate cancer with perineural invasion. The specialist
requested additional studies to determine if the patient’s cancer had
spread. The provider ordered a medium-priority nuclear medicine
bone scan to evaluate for possible metastatic cancer due 1.5 months
later. The specialty follow-up appointments to determine cancer
treatment were pending completion of this and other studies;
therefore, the provider should have ordered the scan urgently as high
priority.
• More than 1.5 months later, also in case 16, an oncology specialist
saw the patient for an initial prostate cancer evaluation. The
oncologist requested the patient have an in-person specialty follow-
up appointment, but the provider ordered a telemedicine
appointment instead, delaying care to the patient.
• In case 25, on a colonoscopy, the specialist found the patient had a
large rectal mass, likely to be cancerous, and needed an urgent
colorectal surgery referral. The provider ordered the referral for a
slower priority than medically indicated, ordered the wrong location
(telemedicine instead of an in-person appointment), and selected the
wrong type of specialist (general surgeon instead of colorectal
surgeon). Because of these errors, the much-needed colorectal
surgery evaluation did not occur until almost five months later.
• In case 55, the provider ordered a follow-up appointment for a
patient with a spinal infection with neurology instead of
neurosurgery. Staff did not discover the error until approximately 1.5
months later, two days before the incorrect neurology appointment
was scheduled to occur. This delayed the patient’s assessment by the
proper specialist.
Outpatient Documentation Quality
Providers did not always document provider progress notes. We found 15 deficiencies,
nine of which related to nurse communication and were the result of one provider.71 The
remaining six related to orders without documented medical reasoning.
In the EHRS, a patient’s documented problem list provides healthcare staff a snapshot of
the patient’s medical health and should be consistent with a patient’s medical problems.
We identified a pattern of providers not keeping problem lists up to date. Examples
include:
• In case 13, throughout the review period, the provider did not update
the patient’s medical problem list to include sleep apnea and seizure
disorder, both significant medical issues.
71 Deficiencies for missing provider progress notes occurred in cases 14, 15, 17, 18, 24, 54, and 55.
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• In case 14, throughout the review period, the provider did not update
the patient’s diagnoses of diabetes, hypertension, and hyperlipidemia
in the patient’s medical record problem list.
• In case 15, throughout the review period, the provider did not update
the patient’s medical concerns of anemia, history of congestive heart
failure, hypothyroidism, and history of thoracic aorta aneurysm stent
graft repair to the patient’s medical problem list.
Patient Notification Letters
After providers interpret laboratory results, they send test result notification letters. Most
providers performed well in sending letters; however, NKSP had a high rate of
deficiencies, mostly due to one provider. This is discussed further in Clinician On-Site
Inspection area below. Also, when providers sent patient notification letters, the letters
often did not include the four elements as required by policy.72 We found 22 deficiencies,
none of which were significant.
Outpatient Provider Continuity
Generally, the institution offered good provider continuity. Providers were assigned to
specific clinics and specialized medical housing units to ensure continuity of care. We
found one deficiency, which was significant:
• In case 53, the specialized medical housing patient was seen by eight
different providers in a span of 13 appointments. This increased the
risk of medical error.
Clinician On-Site Inspection
OIG clinicians met with medical leadership, providers, and nursing staff. The providers
covered the CTC, the TTA, diagnostics (reception center), restrictive housing unit, and
five clinics. At the time of our inspection, NKSP employed five physicians and four
advanced practice providers (nurse practitioners and physician assistants).
Medical leadership discussed provider staffing challenges. Two providers were on
chronic intermittent illness leave and NKSP had no coverage for provider regularly
accrued time off. In addition, NKSP had one more physician allotment they had given to
headquarters telemedicine with the understanding the telemedicine provider would
support NKSP clinics. However, that telemedicine provider was reassigned, and
headquarters telemedicine had not returned the physician position to NKSP. Therefore,
they were short one provider but did not have an open physician position for recruitment.
To reduce appointment backlogs, medical leadership increased the providers’ daily
appointment schedules to 16 patients per 10-hour workday and 12 patients per eight-hour
workday, including nursing co-consultations. In addition, medical leadership had added
weekend and evening clinics to reduce the backlog.
72 Providers did not send letters in cases 9–18, and 20–25. Letters missing necessary components occurred in
cases 1, 15, 16, 18, 23–25, and 55.
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Several providers mentioned the increase in number of patients was challenging;
however, most were very happy with their leadership, fellow providers, and nursing
support. NKSP was one of the institutions able to offer the 15% increase pay differential
to attract providers. NKSP also offered a ten-hour workday, which most providers took
advantage of, citing the benefits of decreased commuting time and reduced stress overall.
NKSP leadership and staff had differing views on the emergency process. Medical
leadership and providers stated urgent and emergent transports took the same transport
time to the emergency department. However, custody and nursing leadership mentioned
the transport times were not the same. The ambulance may travel at the same speed
regardless of emergency designation; however, custody was expected to have a transport
team assembled for emergency transport immediately, whereas the expectation for urgent
transport was assembly within 20 minutes.
Medical leadership mentioned specialty schedulers did not schedule specialty
appointments based on the priority time frame ordered. Rather, they placed the patient in
the next available specialty appointment regardless of the priority time frame. In light of
this, they felt the actual priority ordered was not important. The OIG case review team
disagrees. As NKSP is a reception center, most patients would transfer to another
institution, sometimes before the specialty appointment occurs. CCHCS policy states,
when a patient transfers to another institution, the receiving institution must schedule
that appointment within the originally ordered compliance time frame, not the scheduled
appointment date. The practice of ordering specialty referrals with a delayed compliance
date places patients at risk of delayed specialty medical care.
Notably, the provider with the most deficiencies for missing patient notification letters
stated he was not aware patient notification letters were required or that letters had
required components. Also, the provider with the most deficiencies for missing progress
notes was the physician who would oversee the CTC patients but round on them only one
day a week.73 This CTC physician also worked full-time in other NKSP clinics, and
nursing staff frequently contacted this physician for CTC patient orders in the evenings
while he was working in other clinics. These factors made completing appropriate
documentation difficult.
73 An advanced practice provider was present daily.
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Recommendations
• Medical leadership must familiarize themselves with the different
time frames associated with emergency transport versus urgent
transport as established in state and local policy. Medical leadership
should also develop and implement strategies to educate and train
providers on the differences in these time frames to ensure orders
designation appropriate transport levels.
• Medical leadership should determine the cause(s) of challenges to
providers ordering specialty services for medically appropriate
priorities and time frames and implement remedial measures as
appropriate.
• Medical leadership should determine the cause(s) of challenges to
providers completing appropriate medical documentation, including
on-call progress notes and updated patient medical problem lists and
implement remedial measures as appropriate.
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Reception Center
This indicator focuses on the management of medical needs and continuity of care for
patients arriving from outside the department’s system. The OIG review includes
evaluating the institution’s performance in 1) providing and documenting initial health
screenings, initial health assessments, continuity of medications, and completion of
required screening tests; 2) addressing and providing significant accommodations for
disabilities and health care appliance needs; and 3) identifying health care conditions
needing treatment and monitoring. Patients reviewed for reception center (RC) care are
those received from nondepartmental facilities, such as county jails.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (71.7%)
In case review, NKSP generally delivered good reception center medical care. We found
nurses generally completed the initial health screening forms and performed thorough
assessments. In addition, staff performed well in medication continuity and provided
timely specialty service appointments. In contrast, providers needed improvement in
completing timely provider H&P examinations. After reviewing all aspects, the OIG rated
the case review component of this indicator adequate.
Compliance testing showed NKSP staff performed well in completing the initial health
screening form and maintaining medication continuity for patients arriving from the
county jails. However, NKSP staff needs improvement with timely completing screening
intake tests. Based on the overall compliance score result, the OIG rated the compliance
component of this indicator inadequate.
Case Review and Compliance Testing Results
Our clinicians reviewed eight reception center cases with 27 events. The clinicians
identified 17 deficiencies, five of which were significant.74
Provider Access
Both compliance testing and case reviewers revealed reception center provider access
needed improvement. New patients from county jails intermittently received the required
provider performed physical examinations, including H&Ps, within seven days (MIT
12.004, 60.0%). Similarly, OIG clinicians found, in four out of eight reception center cases,
the provider did not timely evaluate the patients for an H&P.75 Please refer to the Access
to Care indicator for further details.
74 Deficiencies occurred in cases 1, 2, 8, 23, 24, and 32–34. Significant deficiencies occurred in cases 1, 8, and 32.
75 Provider access deficiencies occurred in cases 2, 8, 32, and 33. Significant deficiencies occurred in cases 8 and
32.
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Nursing Performance
OIG clinicians found nurses generally completed the initial health screening forms and
performed thorough assessments. Compliance testing showed nurses performed very well
in completing the initial health screening forms thoroughly (MIT 12.001, 90.0%) and
performed perfectly in completing the assessment and disposition sections (MIT 12.002,
100%). However, we reviewed eight cases of patients who arrived via the reception center
and identified five nursing performance deficiencies, none of which were significant. The
following are examples:
• In case 34, the RN assessed a patient newly arrived from the county
jail with multiple chronic conditions and a colostomy bag. The nurse
did not assess the patient’s abdominal area for a skin assessment or
ensure the patient had wound care supplies for the colostomy bag
changes. Fortunately, the provider saw the patient the following day
and ordered colostomy supplies as well as a LVN follow-up for
wound care.
• Also in case 34, the nurse incorrectly documented the patient did not
have any pending medical appointments. However, the patient
arrived with pending specialty referrals to cardiology,
gastroenterology, neurology, and radiology.
Compliance testing showed staff offered screening intake tests; however, staff only
intermittently completed the tests timely (MIT 12.005, 65.0%). In contrast, our OIG
clinicians found staff generally completed the screening intake tests on time. Compliance
testing further showed the institution performed very well in maintaining medication
continuity for patients arriving from the county jail (MIT 7.004, 90.0%) and ensuring
specialty service appointments occurred timely (MIT 1.008, 93.3%). Our case review
clinicians reached similar findings.
Clinician On-Site Inspection
During the clinician on-site inspection, we toured the new diagnostics area that opened
in June 2023. The diagnostics area connected to the R&R area and allowed for same day
RC processing of new arrivals by nursing, medical, dental, laboratory, and mental health
services. The diagnostics area did not contain an Omnicell, but if medications were
needed, the nursing staff could obtain those medications from the TTA Omnicell, which
was in close proximity.
The RC nursing staff were knowledgeable about their job duties and the reception intake
process. The RC had two RNs and two nurse practitioners. An RC RN was assigned both
in the morning and evening shift. In addition, another RC RN was assigned during the
swing shift.
The CNE reported challenges with constant RC movement of approximately 300 RC
patients weekly. The nursing staff reported between 60 to 220 RC departures to other
institutions per day. Additionally, according to policy, one week prior to a patient’s
transfer from county jail to a RC, custody notifies the RC by email of the patients who
would be arriving. However, the nursing staff reported they frequently did not receive a
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bus list from the county jail in advance for the new arrivals. Instead, they usually learned
of incoming new patients when the patient arrived at NKSP.
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Compliance Score Results
Table 16. Reception Center
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: Did nursing staff complete the
initial health screening and answer all screening questions upon arrival of 18 2 0 90.0%
the patient at the reception center? (12.001) *
For patients received from a county jail: Did the RN complete the
assessment and disposition section, and sign and date the completed
19 0 1 100%
health screening form upon patient’s arrival at the reception center?
(12.002) *
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 required 0 0 20 N/A
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 to 12 8 0 60.0%
07-2022) or five working days (effective 07-2022)? (12.004) *
For patients received from a county jail: Were all screening tests offered or
13 7 0 65.0%
completed within specified timelines? (12.005) *
For patients received from a county jail: Did the primary care provider
review and communicate the intake test results to the patient within 6 14 0 30.0%
specified timelines? (12.006)
For patients received from a county jail: Was a coccidioidomycosis (Valley
17 3 0 85.0%
Fever) skin test offered, administered, read, or refused timely? (12.007)
Overall percentage (MIT 12): 71.7%
Source: The Office of the Inspector General medical inspection results.
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Table 17. Other Tests Related to Reception Center
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: Were all medications ordered by
the institution’s reception center provider made available, administered, or 9 1 10 90.0%
delivered to the patient within the required time frames? (7.004) *
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the challenges providers
encounter when completing H&P examinations within required time
frames, as required by CCHCS policy, and implement remedial
measures as appropriate.
• NKSP leadership should determine the root cause(s) of patients not
receiving Reception Center laboratory services timely and implement
remedial measures as appropriate.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing,
monitoring, and intervening for medically complex patients requiring close medical
supervision. Our inspectors also evaluated the timeliness and quality of provider and
nursing intake assessments and care plans. We assessed staff members’ performance in
responding promptly when patients’ conditions deteriorated, and we looked for good
communication when staff consulted with one another while providing continuity of
care. Our clinicians also interpreted relevant compliance results and incorporated them
into this indicator. At the time of our inspection, NKSP’s specialized medical housing
consisted of a correctional treatment center (CTC).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (48.0%)
Case review found NKSP performed satisfactorily in this indicator. Compared to Cycle 6,
we reviewed a greater number of provider and nursing events. Similar to Cycle 6, we
found providers evaluated their patients within the required time frames and delivered
good care. The nurses rounded on patients routinely and generally notified the provider
when they identified abnormal findings. However, we found opportunities for
improvement in nursing assessments, documentation, and peripherally inserted central
catheter (PICC) line care. Overall, the OIG rated the case review component of this
indicator adequate.
Compared with Cycle 6, compliance testing showed NKSP needed improvement in this
indicator. NKSP performed excellently in completing initial assessments and in
completing H&P examinations within required time frames. However, records contained
poor medication continuity for patients newly admitted to specialized medical housing.
Compliance testing also revealed the CTC did not maintain an operational call system to
ensure patients have access to care, and the CTC staff did not perform patient safety
checks timely. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed four CTC cases with 88 events that included 32 provider events and 20
nursing events. Due to the frequency of nursing and provider contacts in the specialized
medical housing, we bundled up to two weeks of patient care into a single event. We
identified 33 deficiencies, four of which were significant.76
76 Deficiencies occurred in cases 24 and 53–55. Significant deficiencies occurred in cases 53 and 55.
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Provider Performance
Providers delivered good care to the specialized medical housing patients. Compliance
testing showed providers performed excellently in obtaining timely admission H&P (MIT
13.002, 100%). OIG clinicians reviewed 32 specialized medical housing provider events in
four cases and did not identify any delays in admission H&Ps. Providers completed their
rounds at clinically appropriate intervals, generally developed good care plans, and made
sound medical decisions. We found a pattern of seven missing provider progress notes
omitted by one provider, but none were significant. In addition, we identified one
significant deficiency related to incorrect specialty services orders, which is discussed in
the Provider Performance indicator.77
Nursing Performance
Compliance testing showed CTC nurses performed excellently in providing timely
admission assessments (MIT 13.001, 100%). The OIG clinicians reached similar findings.
OIG clinicians concluded, of the 33 deficiencies identified in the CTC cases, 17
deficiencies related to nursing performance, two of which were significant.78 CTC nurses
conducted regular rounds and generally provided satisfactory care. However, our
clinicians found opportunities for improvement in performing thorough nursing
assessments, documentation, and PICC line care.
• In case 53, the RN obtained the patient’s vital signs during CTC
rounds, and the patient had an abnormally elevated heart rate.
However, the RN did not recheck the patient’s heart rate or notify
the provider. In another event, an RN evaluated the patient for
abdominal cramping. The RN did not describe the abdomen
appearance or palpate the abdomen. Additionally, the nurse
documented “unable to assess” bowel sounds; however, we found no
signed refusal form on file.
• In case 54, the patient with disseminated cocci had a PICC line for
IV fluids and IV antibiotics. The CTC nurses performed daily
assessments, provided wound care to the left chest, and
communicated well with the laboratory staff to ensure they received
STAT laboratory results and notified the PCP. However, we
identified opportunities for improvement in assessments of intake
and output, PICC line care, and skin assessments. For example, the
CTC nurses did not always change the PICC line caps with weekly
dressing changes and did not always flush the PICC line after
administering IV antibiotics.
• In case 55, the patient had osteomyelitis (bone infection causing
inflammation) and had a PICC line for antibiotics. During the review
period, the nurses frequently did not document assessments of the
77 Provider performance deficiencies occurred in cases 53–55. The two significant deficiencies occurred in cases
53 and 55. The documentation deficiencies occurred in cases 54 and 55.
78 Nursing performance deficiencies occurred in cases 24 and 53–55. Two significant deficiencies occurred in
case 55.
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PICC line for appearance or signs of infection and did not measure
the external line to ensure proper placement when administering IV
antibiotics. We identified opportunities for improvement in PICC
line care; however, they did not impact the care provided. The
patient completed the antibiotics, discharged to outpatient housing,
and was followed closely by the infectious disease and neurosurgery
specialists.
Compliance testing showed NKSP performed poorly in maintaining an operational call
system to ensure CTC patients have access to care, and the CTC staff performed poorly
in conducting patient safety checks timely (MIT 13.101 and 13.102, zero). At the time of
the compliance team’s on-site inspection, the CTC call light system was in disrepair. In
addition, although rounding checks must be completed every 15 minutes, during the
compliance testing on-site, we discovered the nursing service call light system rounds
checklist was missing documentation of rounding checks for more than three hours.
Medication Administration
Compliance testing showed NKSP performed poorly in ensuring patients admitted to the
CTC received their medications timely (MIT 13.003, 40.0%). Our clinicians identified one
deficiency related to medication management, which was not significant.79 Please refer to
the Medication Management indicator for further details.
Clinician On-Site Inspection
The institution had six medical CTC beds and ten CTC mental health beds. NKSP had
two designated negative pressure rooms, which are designed to minimize the spread of
airborne infection. During the OIG clinician on-site inspection, patients occupied six
medical beds and eight patients occupied the mental health beds.
The CTC had 24-hour nursing staff. The CTC nursing staff informed the OIG clinicians
they were assigned on the morning shift with a lead RN, one medical RN, one mental
health RN, one psychiatric technician, one LVN, and one CNA as needed. On the evening
shift, they had one lead RN, a medical and mental health RN, and one psychiatric
technician. On graveyard shift, staffing included one lead RN, one medical RN, and one
mental health RN. The lead RNs conducted audits on every shift and performed a random
sample audit with new admissions after three days to ensure documentation was
complete.
Our clinicians observed the CTC huddle, which was well attended and included the
nurses, medical and mental health providers, recreational therapist, dietician, utilization
management nurse, SRN, and custody staff. They discussed pertinent patient information
including on-site/off-site specialty appointments, admissions, discharges, refusals of vital
signs, and medication compliance.
The OIG clinicians interviewed the CTC RNs and found they were knowledgeable
regarding the PICC line care, flushes, assessment, and documentation. The nurses stated
the RNs on every shift completed a head-to-toe assessment and vital signs. The nursing
staff reported PICC line flush orders could be confusing; however, they would contact the
79 A medication management deficiency occurred in case 55.
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provider if they found discrepancies in the orders. The nursing staff also reported, for
patients who were on continuous IV fluids, they did not measure the urine output but
only documented the patient’s report of the number of times they urinated. However, the
CTC nurses acknowledged, under their local operating procedures, they should have been
documenting the measurement of fluid intake or urine output, not the number of times
the patient reported urinating.
Compliance On-Site Inspection
At the time of on-site inspection, the CTC had a nonfunctional call light system (MIT
13.101, zero), and the CTC patients’ safety check log had several missing entries.
Thorough completion of the safety check log is required in the institution’s local
operating procedure in the event the call light system is inoperable (MIT 13.102, zero).
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Compliance Score Results
Table 18. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Did the registered nurse complete an initial
10 0 0 100%
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
10 0 0 100%
required time frame? (13.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 4 6 0 40.0%
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call 0 1 0 0
system? (13.101)
For specialized health care housing (CTC, SNF, hospice, OHU): Do health
care staff perform patient safety checks according to institution’s local 0 1 0 0
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): 48.0%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should determine the challenges preventing CTC
nursing staff from completing thorough patient assessments,
including PICC line care, and from completing thorough
documentation. Nursing leadership should implement remedial
measures as appropriate.
• Nursing leadership should determine the challenges preventing CTC
nursing staff from completing the call light system rounding
checklist every 15 minutes as per the local operating procedures and
should implement remedial measures as appropriate.
• The institution should ascertain the root cause(s) related to why
medications are not consistently available and administered in a
timely manner to specialized medical housing patients and should
implement remedial measures as appropriate.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. The OIG
clinicians focused on the institution’s performance in providing needed specialty care.
Our clinicians also examined specialty appointment scheduling, providers’ specialty
referrals, and medical staff’s retrieval, review, and implementation of any specialty
recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (87.4%)
OIG case review found NKSP’s performance in specialty services was good. Specialty
services usually occurred as ordered; however, we found providers often ordered specialty
services for inappropriate priority time frames. Nurses performed satisfactorily with
patient assessments when patients returned from off-site specialty appointments. We
found specialty reports were not always scanned timely, but once scanned, providers
usually endorsed them within the required time frames. Overall, the OIG rated the case
review component of this indicator adequate.
Compliance testing showed NKSP performed excellently in specialty services. Staff
almost always timely provided initial routine-priority specialty services and subsequent
follow-up appointments for medium- and routine-priority specialty services. Staff also
timely retrieved and endorsed high-priority specialty reports. However, compliance
testing resulted in low scores for providing preapproved specialty services. Based on the
overall compliance score result, the OIG rated the compliance component of this
indicator proficient.
Case Review and Compliance Testing Results
The OIG clinicians reviewed 85 specialty services events, including 55 specialty
encounters, 24 nursing encounters, and six provider encounters. We found 26 deficiencies
in this category, five of which were significant.80
Access to Specialty Services
NKSP performed very well in meeting specialty referral compliance dates. Compliance
testing showed staff performed satisfactorily in completing most high-priority
appointments (MIT 14.001, 80.0%), performed well in completing medium-priority
appointments (MIT 14.004, 86.7%), and performed excellently in completing routine
specialty appointments within required time frames (MIT 14.007, 100%). Case reviewers
80 Deficiencies occurred in cases 1, 15–18, 20, 21, 23, 25, 53, and 55. Significant deficiencies occurred in cases 16,
23, 25, and 54.
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identified four access to specialty care deficiencies related to missed compliance dates,
one of which was significant:81
• In case 54, the provider ordered a follow-up GI specialty
appointment for a patient with severe iron deficiency anemia and
possible gastrointestinal bleeding. The specialty appointment
occurred almost one month late.
Compliance testing showed NKSP needed improvement in ensuring specialty access for
patients who transferred into the institution with a preapproved specialty request (MIT
14.010, 63.6%).
Provider Performance
Provider performance in specialty services was mixed. Compliance testing showed
patients almost always saw their providers or nurses promptly after specialty services
(MIT 1.008, 93.3%). Case review did not identify any deficiencies in follow up after
specialty services.
Case review identified nine deficiencies in which providers ordered specialty
appointments with medically inappropriate time frames, five of which were significant. 82
High-priority referrals have a two-week compliance time frame, medium-priority
referrals have up to a 45-day compliance time frame and routine-priority referrals have up
to a 90-day compliance time frame. Several referrals ordered for medium or routine
priority should have been ordered as high priority. Ordering referrals for a medically
inappropriate, delayed time frame artificially increases the appearance of compliance
with the CCHCS compliance dashboards but increases risks to the patients.
We also identified provider errors in the location or type of specialty appointments
ordered which also delayed care to the patients. These issues are discussed in more detail
in the Provider Performance indicator.
Nursing Performance
NKSP nurses performed adequately in assessing patients who returned to the institution
from off-site appointments. The specialty nurses provided pertinent patient records for
the off-site specialists to review and generally communicated specialist recommendations
to the providers. Case review identified five deficiencies, none of which were
significant.83
Health Information Management
Compliance testing showed staff performed satisfactorily in scanning specialty reports
within required time frames (MIT 4.002, 83.3%). Provider performance was excellent for
retrieving and endorsing high-priority specialty reports (MIT 14.002, 100%) and was
81 Deficiencies occurred in cases 21, 25, 54, and 55.
82 Provider specialty deficiencies occurred in cases 1, 16, 25, and 55. Significant deficiencies occurred in cases
16, 25, and 55.
83 Deficiencies occurred in cases 17, 18, 20, and 53. None were significant.
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satisfactory for retrieving and endorsing medium- and routine-priority specialty reports
(MIT 14.005, 80.0% and MIT 14.008, 80.0%).
Of the 55 specialty services appointments in case review samples, clinicians found nine
deficiencies related to HIM, with a pattern of specialty reports scanned late. The
following are examples:
• In case 15, a cardiologist saw the patient; however, staff scanned the
specialty report late.
• In case 18, the patient had an EGD and colonoscopy.84 Staff only
scanned preliminary reports into the EHRS and did not scan the final
reports.
• In case 54, an infectious disease specialist saw the patient; however,
staff scanned the specialty report two weeks late.
Clinician On-Site Inspection
We discussed specialty services processes with specialty services staff, office technicians,
health information management supervisors, ancillary staff, diagnostic staff, nurses, and
providers. Staff reported no significant staffing shortages among specialty services staff
during the review period.
The medical records supervisor and specialty services RNs described the process of
retrieving on-site and off-site reports. The off-site specialty RN was responsible for
obtaining final off-site specialty reports. NKSP had access to their local hospital medical
record system, which expedited specialty report receipt from appointments occurring
within that system. Upon return from an off-site appointment, the TTA RN would assess
the patient and collect any specialty paperwork returned with the patient. HIM staff
picked up the specialty paperwork the next morning and scanned it into the medical
record.
The on-site specialty RN obtained the on-site specialist’s reports and obtained
handwritten provider endorsement signatures, if possible. HIM staff then would scan the
paper reports into the EHRS. After scanning into the EHRS, staff electronically sent the
specialty reports to the patient’s primary care provider for review and endorsement.
Specialty services staff discussed intermittent backlogs during the review period. NKSP
had difficulty obtaining transgender evaluation appointments (which occurred through
telemedicine), speech therapy evaluations, and orthopedic appointments. Orthopedic
appointments could be problematic because they often occurred in batches of multiple
patients at one time.
To ensure staff scheduled patients for telemedicine appointments within their
compliance dates, NKSP developed a process where staff would forward high-priority,
medium-priority, and routine-priority telemedicine appointment requests that were
84 An EGD is an esophagogastroduodenoscopy. In this procedure, the specialist uses a camera to examine the
esophagus and the stomach.
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within 10, 14, and 30 days of compliance, respectively, to the off-site specialty RN to
schedule with an off-site specialist.
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Compliance Score Results
Table 19. Specialized 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 15 0 0 100%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 5 1 9 83.3%
(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 3 0 80.0%
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 15 0 0 100%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 12 3 0 80.0%
frame? (14.008)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 2 0 13 100%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
7 4 0 63.6%
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
10 0 0 100%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
6 2 2 75.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 87.4%
Source: The Office of the Inspector General medical inspection results.
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Table 20. Other Tests Related to Specialized Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up visits
42 3 0 93.3%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
25 5 15 83.3%
within five calendar days of the encounter date? (4.002)
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the root cause(s) of providers
not ordering specialty services within medically appropriate time
frames 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 properly 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 adequately addressed program performance. In addition, our
inspectors determined whether the institution provided training and job performance
reviews for its employees. We checked whether staff possessed current, valid professional
licenses, certifications, and credentials. The OIG rated this indicator solely based on the
compliance score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (71.0%)
NKSP’s performance was mixed in this indicator. While NKSP scored well in some
applicable tests, performance needed improvement in several areas. The EMRRC did not
always complete the required checklists and review cases within required time frames.
The local governing body did not timely complete documentation. While staff conducted
medical emergency response drills, the nursing education department emergency
response drill forms were all either incomplete or missing. In addition, the nursing
department did not ensure newly hired nurses timely received the required onboarding
training. These findings are set forth in the table on the next page. Based on the overall
compliance score result, the OIG rated the compliance component of this indicator
inadequate.
Compliance Testing Results
Nonscored Results
At NKSP, 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. At the time of our
inspection, for eight patients, we found no evidence in the submitted documentation that
preliminary mortality reports were completed. These reports were overdue at the time of
the OIG’s inspection (MIT 15.998).
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Compliance Score Results
Table 21. 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
2 10 0 16.7%
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 1 3 0 25.0%
procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during each
watch of the most recent quarter, and did health care and custody staff 0 3 0 0
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
7 0 0 100%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
9 2 0 81.8%
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 13 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 6 0 1 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 1 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
0 1 0 0
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG medical This is a nonscored test. Please refer to Table 3
inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 71.0%
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 NKSP
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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 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. NKSP Case Review Sample Sets
Sample Set Total
CTC/OHU 3
Death Review/Sentinel Events 2
Diabetes 5
Emergency Services – CPR 5
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 6
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 18
Reception Center Transfers 3
Specialty Services 1
55
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Table B–2. NKSP Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 3
Anticoagulation 1
Arthritis/Degenerative Joint Disease 3
Asthma 11
Cancer 4
Cardiovascular Disease 1
Chronic Kidney Disease 3
Chronic Pain 6
Cirrhosis/End-Stage Liver Disease 2
Coccidioidomycosis 2
COPD 1
Deep Venous Thrombosis/Pulmonary Embolism 1
Diabetes 5
Gastroesophageal Reflux Disease 4
HIV 1
Hepatitis C 14
Hyperlipidemia 14
Hypertension 17
Mental Health 23
Seizure Disorder 2
Sleep Apnea 3
Substance Abuse 16
Thyroid Disease 1
138
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Table B–3. NKSP Case Review Events by Program
Diagnosis Total
Diagnostic Services 161
Emergency Care 43
Hospitalization 19
Intrasystem Transfers In 8
Intrasystem Transfers Out 7
Outpatient Care 267
Reception Center Care 27
Specialized Medical Housing 88
Specialty Services 103
723
Table B–4. NKSP Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 20
MD Reviews Focused 5
RN Reviews Detailed 14
RN Reviews Focused 35
Total Reviews 73
Total Unique Cases 55
Overlapping Reviews (MD & RN) 19
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Appendix C: Compliance Sampling Methodology
North Kern State Prison
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least one
Patients condition per patient — any risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 30 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 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 or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 30 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 25 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 25 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 11 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 — 20 OIG Q: 12.001 • See Reception Center
Medication Orders
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 10 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies OIG inspector • Identify and inspect clinical & med
Areas by test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site clinical
Preparation and by test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 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 9 On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications medication listing medications for IPs housed in
restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001 – 007 Recent Deliveries N/A at this OB Roster • Delivery date (2 – 12 months)
institution • Most recent deliveries (within date
range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2 – 12 months)
institution • Earliest arrivals (within date range)
Preventive Services
MITs 9.001 – 002 TB Medications 25 Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months
or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever 19 Cocci transfer • Reports from past 2 – 8 months
status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 007 RC 20 SOMS • Arrival date (2 – 8 months)
• Arrived from (county jail, return from
parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001 – 003 Specialized Health 10 CADDIS • Admit date (2 – 8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
• Rx count
• Randomize
MITs 13.101 – 102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, and radiology services
• Randomize
MITs 14.004 – 006 Medium-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, and radiology services
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Specialty Services (continued)
MITs 14.007 – 009 Routine-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C,
HIV, orthotics, gynecology,
consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, and
radiology services
• Randomize
MIT 14.010 Specialty Services 11 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 10 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
MIT 15.103 Death Reports 7 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations (continued)
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 11 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 13 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site certification • All staff
Response tracking logs • Providers (ACLS)
Certifications • Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
MIT 15.109 Pharmacy and All On-site listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
document
MIT 15.110 Nursing Staff New All Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998 CCHCS Mortality 8 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
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California Correctional Health Care Services’
Response
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November 25, 2024, OIG Response to November 18, 2024,
Letter Regarding NKSP Report
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Office of the Inspector General, State of California Inspection Period: November 2022 – April 2023 Report Issued: November 2024
Cycle 7
Medical Inspection Report
for
North Kern State Prison
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Neil Robertson
Chief Deputy Inspector General
STATE of CALIFORNIA
November 2024
OIG