OIG
Pelican Bay State Prison Cycle 6 Medical Inspection Report
Read the report at CDCR ↗
Amarik K. Singh, Inspector General
OFFICE of the
OIG
INSPECTOR GENERAL
Independent Prison Oversight March 2022
Cycle 6
Medical Inspection
Report
Pelican Bay State Prison
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Cycle 6, Pelican Bay State Prison | i
Contents
Introduction 1
Summary 3
Overall Rating: Adequate 3
Medical Inspection Results 7
Deficiencies Identified During Case Review 7
Case Review Results 7
Compliance Testing Results 8
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 14
Access to Care 14
Diagnostic Services 22
Emergency Services 26
Health Information Management 30
Health Care Environment 34
Transfers 42
Medication Management 47
Preventive Services 54
Nursing Performance 56
Provider Performance 63
Specialized Medical Housing 67
Specialty Services 72
Administrative Operations 77
Appendix A. Methodology 81
Case Reviews 82
Compliance Testing 85
Indicator Ratings and the Overall Medical Quality Rating 86
Appendix B. Case Review Data 87
Appendix C. Compliance Sampling Methodology 90
California Correctional Health Care Services’ Response 98
Cycle 6, Pelican Bay State Prison | ii
Illustrations
Tables
1. Pelican Bay State Prison Summary Table 3
2. Pelican Bay State Prison Policy Compliance Scores 4
3. Pelican Bay State Prison Master Registry Data as of January 2021 5
4. Pelican Bay State Prison Health Care Staffing Resources as of January 2021 6
5. Pelican Bay State Prison Results Compared with State HEDIS Scores 10
6. Access to Care 19
7. Other Tests Related to Access to Care 20
8. Diagnostic Services 24
9. Health Information Management 32
10. Other Tests Related to Health Information Management 33
11. Health Care Environment 40
12. Transfers 45
13. Other Tests Related to Transfers 46
14. Medication Management 52
15. Other Tests Related to Medication Management 53
16. Preventive Services 55
17. Specialized Medical Housing 70
18. Specialty Services 75
19. Other Tests Related to Specialty Services 76
20. Administrative Operations 79
A–1. Case Review Definitions 82
B–1. Case Review Sample Sets 87
B–2. Case Review Chronic Care Diagnoses 88
B–3. Case Review Events by Program 89
B–4. Case Review Sample Summary 89
Figures
A–1. Inspection Indicator Review Distribution 82
A–2. Case Review Testing 84
A–3. Compliance Sampling Methodology 85
Photographs
1. Clinic outdoor waiting area 34
2. Clinic indoor waiting area 35
3. Torn examination room table cover 36
4. Torn pillow cover used for Physical Therapy services 36
5. Examination room configuration did not allow patients to lie fully extended without obstruction 37
6. Expired medical supply dated August 1, 2020 37
7. Unlabeled medical supplies 38
8. Exhaust under the clinic sink had accumulated dust 39
Cover: Rod of Asclepius courtesy of Thomas Shafee
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay 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 persons1 in the California Department of Corrections and
Rehabilitation (the department).2
In Cycle 6, the OIG continues to apply the same assessment
methodologies used in Cycle 5, including clinical case review and
compliance testing. These methods provide 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. This information helps to assess the performance of the institution
in providing sustainable, adequate care.3
We continue to review institutional care using 15 indicators, as in prior
cycles. 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).4 We
determine a total compliance score for each applicable indicator and
consider the MIT scores in the overall conclusion of the institution’s
performance. In addition, our clinicians complete document reviews of
individual cases and perform on-site inspections, which include
interviews with staff.
In reviewing the cases, our clinicians examine whether providers 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.5 At the same time, our clinicians examine whether the
institution’s medical system mitigated the error. The OIG rates the
indicators as proficient, adequate, or inadequate.
1 In this report, we use the terms patient and patients to refer to incarcerated persons.
2 The OIG’s medical inspections are not designed to resolve questions about the
constitutionality of care, and the OIG explicitly makes no determination regarding the
constitutionality of care the department provides to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer
selected Healthcare Effectiveness Data and Information Set (HEDIS) measures for
comparison purposes.
4 The department regularly updates its policies. The OIG updates our policy-compliance
testing to reflect the department’s updates and changes.
5 If we learn of a patient needing immediate care, we notify the institution’s chief executive
officer.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 2
The OIG has adjusted Cycle 6 reporting in two ways. First,
commencing with this reporting period, we interpret compliance and
case review results together, providing a more holistic assessment of
the care; and second, we consider whether institutional medical
processes lead to identifying and correcting provider or system errors.
The review assesses the institution’s medical care on both system and
provider levels.
As in Cycle 5, 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 6 inspection of Pelican Bay State Prison (PBSP), the
receiver had delegated this institution back to the department.
We completed our sixth inspection of PBSP, and this report presents
our assessment of the health care provided at that institution during the
inspection period between November 2020 and April 2021.6 The data
obtained for PBSP and the on-site inspections occurred during the
COVID-19 pandemic.7
PBSP is located in Crescent City in Del Norte County. PBSP has one
Level I minimum-security yard, one facility housing Level II patients,
and two Level IV yards housing maximum-security patients in a general
population setting. In addition, PBSP has a security housing unit (SHU)
facility, which was designed for individuals who present serious
management concerns, including prison gang members and violent
maximum-security patients. The institution operates multiple clinics
where medical staff handle nonurgent requests for medical services. It
also provides inpatient care at its correctional treatment center (CTC)
and treats patients needing urgent or emergent care in its triage and
treatment area (TTA). PBSP has been designated by CDCR as a basic
care prison, secondary to its location in a rural area away from tertiary
care centers and specialty care providers whose services would likely be
frequently used by higher-risk patients.
6 Samples are obtained per case review methodology shared with stakeholders in prior
cycles. The case reviews include cardiopulmonary resuscitation (CPR) reviews between
August 2020 and February 2021, death reviews between January 2020 and March 2021, and
RN sick call reviews between August 2020 and April 2020.
7As of October 5, 2021, the department reports on its public tracker that 78% of the incarcerated
population at PBSP is fully vaccinated while 42% of PBSP staff are fully vaccinated:
https://www.cdcr.ca.gov/covid19/population-status-tracking/
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 3
Summary
We completed the Cycle 6 inspection of PBSP in September 2021.
OIG inspectors monitored the institution’s medical care that
occurred between November 2020 and April 2021.
The OIG rated the overall quality of health care at PBSP as
adequate. We list the individual indicators and ratings applicable
to this institution in the PBSP Executive Summary Table below.
Table 1. PBSP Summary Table
Cycle 6 Cycle 6 Cycle 6 Change
Health Care Indicators Case Review Compliance Overall Since
Rating Rating Rating Cycle 5
Access to Care Adequate Adequate Adequate
Diagnostic Services Adequate Adequate Adequate
Emergency Services Adequate N/A Adequate
Health Information Management Adequate Inadequate Adequate
Health Care Environment N/A Inadequate Inadequate
Transfers Adequate Adequate Adequate
Medication Management Proficient Inadequate Inadequate
Prenatal and Postpartum Care N/A N/A N/A N/A
Preventive Services N/A Adequate Adequate
Nursing Performance Adequate N/A Adequate
Provider Performance Adequate N/A Adequate
Reception Center N/A N/A N/A N/A
Specialized Medical Housing Adequate Proficient Adequate
Specialty Services Adequate Inadequate Inadequate
Administrative Operations† N/A Proficient Proficient
* The symbols in this column correspond to changes that occurred in indicator ratings between the medical
inspections conducted during Cycle 5 and Cycle 6. The equals sign means there was no change in the rating. The
single arrow means the rating rose or fell one level, and the double arrow means the rating rose or fell two levels
(green, from inadequate to proficient; pink, from proficient to inadequate).
† Administrative Operations is a secondary indicator and is not considered when rating the institution’s overall
medical quality.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 4
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 315 patient records and 874 data points and used
the data to answer 87 policy questions. In addition, we observed PBSP’s
processes during an on-site inspection in June 2021. Table 2 below lists
PBSP’s average scores from Cycles 4, 5, and 6.
Table 2. PBSP Policy Compliance Scores
Scoring Ranges
100%–85.0% 84.9%–75.0% 74.9%–0
Medical Cycle 4 Cycle 5 Cycle 6
Inspection Policy Compliance Category Average Average Average
Tool (MIT) Score Score Score
1 Access to Care 89.4% 86.5% 79.7%
2 Diagnostic Services 89.8% 75.2% 82.2%
4 Health Information Management 44.3% 83.1% 64.2%
5 Health Care Environment 85.0% 71.5% 67.9%
6 Transfers 93.8% 56.0% 77.1%
7 Medication Management 87.7% 72.2% 64.4%
8 Prenatal and Postpartum Care N/A N/A N/A
9 Preventive Services 76.4% 95.5% 83.4%
12 Reception Center N/A N/A N/A
13 Specialized Medical Housing 98.0% 95.0% 85.0%
14 Specialty Services 83.3% 91.0% 54.2%
15 Administrative Operations 74.4%* 84.3% 86.5%
* In Cycle 4, there were two secondary (administrative) indicators, and this score reflects the average of
those two scores. In Cycle 5 and moving forward, the two indicators were merged into one, with only one
score as the result.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 5
The OIG clinicians (a team of physicians and nurse consultants)
reviewed 47 cases, which contained 950 patient-related events. After
examining the medical records, our clinicians conducted a follow-up
on-site inspection 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 2 inadequate. Our
physicians did not identify any adverse events during this inspection.
The OIG then considered the results from both case review and
compliance testing, and drew overall conclusions, which we report in
the 13 health care indicators. Multiple OIG physicians and nurses
performed quality control reviews; their subsequent collective
deliberations ensured consistency, accuracy, and thoroughness. Our
clinicians acknowledged institutional structures that catch and resolve
mistakes that may occur throughout the delivery of care. As noted
above, we listed the individual indicators and ratings applicable for this
institution in Table 1, the PBSP Summary Table.
In May 2021, the Health Care Services Master Registry showed that
PBSP had a total population of 2,085. A breakdown of the medical risk
level of the PBSP population as determined by the department is set
forth in Table 3 below.8
Table 3. PBSP Master Registry Data as of May 14, 2021
Medical Risk Level Number of Patients Percentage
High 1 17 0.8%
High 2 93 4.5%
Medium 489 23.5%
Low 1,486 71.3%
Total 2,085 100.0%
Source: Data for the population medical risk level were obtained
from the CCHCS Master Registry dated 5-14-21.
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 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 6
Based on staffing data the OIG obtained from California Correctional
Health Care Services (CCHCS), as identified in Table 4 below, Pelican
Bay State Prison had zero vacant executive leadership positions, two
vacant primary care provider positions, 1.7 vacant nursing supervisor
positions, and 31.6 vacant nursing staff positions.
Table 4. P BSP Health Care Staffing Resources as of May 2021
Executive Primary Care Nursing Nursing
Positions Leadership* Providers Supervisors Staff† Total
Authorized Positions 6.0 5.0 10.7 86.6 108.3
Filled by Civil Service 6.0 4.0 9.0 55.0 74.0
Vacant 0 2.0 1.7 31.6 35.3
Percentage Filled by Civil Service 100.0% 80.0% 84.1% 63.5% 68.3%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0% 0% 0% 0% 0%
Filled by Registry 0 1 0 20 21.0
Percentage Filled by Registry 0% 20.0% 0% 23.1% 19.4%
Total Filled Positions 6.0 5.0 9.0 75.0 95.0
Total Percentage Filled 100.0% 100.0% 84.1% 86.6% 87.7%
Appointments in Last 12 Months 0 2 1 17 20
Redirected Staff 0 0 0 0 0
Staff on Extended Leave‡ 0 0 0 6 6
Adjusted Total: Filled Positions 6 5 9 69 89
Adjusted Total: Percentage Filled 100% 100% 84.1% 79.7% 82.2%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes 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 6 medical inspection preinspection questionnaire received May 2021, from California Correctional
Health Care Services.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 7
Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm.
An adverse event occurs when the deficiency caused harm to the
patient, highlighting the serious consequences, and providing an
impetus for improvement.9 All major health care organizations identify
and track adverse events. The OIG identifies deficiencies and adverse
events for the benefit of the institution’s quality improvement program.
The OIG did not find any adverse deficiencies at PBSP during the Cycle
6 inspection period.
Case Review Results
OIG case reviewers assessed 10 of the 13 indicators applicable to PBSP.
Of these 10 indicators, OIG clinicians rated one proficient, nine
adequate and zero 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, none were proficient, 18 were adequate,
and two were inadequate. In the 950 events reviewed, there were 129
deficiencies, 30 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 PBSP:
•
Correctional treatment center staff provided good quality
medical care.
•
Staff utilized built-in messaging to communicate patient care
issues quickly and to ensure timely care. On several occasions
specialty nurses messaged providers to ensure timely follow-up
appointments and orders.
•
Providers made good decisions during emergent or urgent
situations.
Our clinicians found PBSP could improve in the following areas:
•
During the Covid-19 pandemic, providers should more carefully
consider whether a patient encounter could be postponed
safely.
9For a definition of an event, see Table A–1, page 73.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 8
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable
to PBSP. Of these 10 indicators, our compliance inspectors rated two
proficient, four adequate, and four inadequate. We tested policy
compliance in the Health Care Environment, Preventative Services, and
Administrative Operations indicators, as these indicators do not have a
case review component.
PBSP demonstrated a high rate of policy compliance in the following
areas:
•
Providers performed well in completing history and physical
examinations within the required time frames.
•
Because the institution’s specialized medical housing unit had
working call buttons, medical staff were able to enter patient
rooms in a timely manner during emergent events.
•
Providers performed exceptionally well in endorsing and
communicating diagnostic services results according to
CCHCS policy.
•
Nursing staff received and reviewed health care services
request forms and conducted face-to-face encounters within
policy time frames.
PBSP demonstrated a low rate of policy compliance in the following
areas:
•
The institution did not perform well in providing specialty
services to patients with approved high-priority, medium-
priority, and routine-priority orders.
•
Providers often did not review specialty services reports within
the required time frames.
•
Patients did not timely receive their ordered chronic care
medications and hospital discharge medications; patients with
a temporary layover at PBSP also did not receive their
medications timely.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 9
Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted
above, the OIG presents selected measures from the Healthcare
Effectiveness Data and Information Set (HEDIS) for comparison
purposes. The HEDIS is a set of standardized quantitative performance
measures designed by the National Committee for Quality Assurance to
ensure that the public has the data it needs to compare the performance
of health care plans. Because the Veterans Administration no longer
publishes its individual HEDIS scores, we removed them from our
comparison for Cycle 6. 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 Kaiser Medi-Cal HEDIS scores for three of five diabetic
measures to use in conducting our analysis, and we present them here
for comparison.
HEDIS Results
We considered PBSP’s performance with population-based metrics to
assess the macroscopic view of the institution’s health care delivery.
PBSP’s results compared favorably with those found in State health
plans for diabetic care measures. We list the nine HEDIS measures in
Table 5.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs (California
Medi-Cal, Kaiser Northern California (Medi-Cal), and Kaiser Southern
California (Medi-Cal), PBSP performed better in all three diabetic
measures that have statewide comparative data: HbA1c screening, Poor
HbA1c control, and blood pressure control.
Immunizations
Statewide comparative data were not available for immunization
measures; however, we include this data for informational purposes.
PBSP had a 55 percent influenza immunization rate for adults 18 to
64 years old, and a 63 percent influenza immunization rate for adults 65
years of age and older.10 The pneumococcal vaccine rate was 70
percent.11
10 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a
reportable result. The sample for older adults did not include a full sample.
11 The pneumococcal vaccines administered are the 13 valent pneumococcal vaccine
(PCV13) 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 the one in which the patient was housed
during the inspection period.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 10
Colorectal Cancer Screening
Statewide comparative data were not available for colorectal cancer
screening; however, we include these data for informational purposes.
PBSP had an 81 percent colorectal cancer screening rate.
Table 5. PBSP Results Compared with State HEDIS Scores
California California
PBSP
Kaiser Kaiser
California NorCal SoCal
Cycle 6 Medi-Cal Medi-Cal Medi-Cal
HEDIS Measure Results* 2018† 2018† 2018†
HbA1c Screening 100% 90% 94% 96%
Poor HbA1c Control (> 9.0%) ‡, § 19% 34% 25% 18%
HbA1c Control (< 8.0%) ‡ 69% – – –
Blood Pressure Control (< 140/90) ‡ 86% 65% 78% 84%
Eye Examinations 80% – – –
Influenza – Adults (18–64) 55% – – –
Influenza – Adults (65+) 63% – – –
Pneumococcal – Adults (65+) 70% – – –
Colorectal Cancer Screening 81% – – –
Notes and Sources
* Unless otherwise stated, data were collected in June 2021 by reviewing medical records from a sample of PBSP’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, 2019–June 30, 2020 (published April 2021).
www.dhcs.ca.gov/documents/MCQMD/CA2019-20-EQR-Technical-Report-Vol3-F2.pdf
‡
For this indicator, the entire applicable PBSP 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 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 11
Recommendations
As a result of our assessment of PBSP’s performance, we offer the
following recommendations to the department:
Access to Care
•
Medical leadership should determine the root cause(s) of
challenges in the timely provision of chronic care follow-up
appointments with providers, nurse-to-provider referrals and
implement remedial measures as appropriate.
•
The department should provide clear policy guidance to
institutions regarding how to manage care during the
pandemic, including how to manage care for chronic care
patients whose appointments might be cancelled or delayed,
how to prioritize patient movement to ensure provider
appointments occur, how to properly close an appointment for
patients who only receive a medical chart review, and how to
balance the workload to ensure equitable distribution of patient
care among nursing and providers.
Emergency Services
•
Nursing leadership should provide additional training to staff
for complete documentation of emergency medical events to
include all appropriate times, interventions provided, report to
EMS personnel, patient reassessments, and communication
with the providers.
•
The Emergency Medical Response Review Committee
(EMRRC) should more thoroughly review emergency response
events and accurately detail findings.
Health Information Management
•
The department should consider adjusting the default drop-
down menu on the results letter in the EHRS so that the menu
defaults to patient letter instead of DDP-Scan; the department
should train providers to generate the results letters
appropriately.
Health Care Environment
•
Nursing leadership should consider performing random spot
checks to ensure staff follow medical supply management
protocols.
•
Nursing leadership should direct each clinic nurse supervisor
to review the monthly emergency medical response bag (EMRB)
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 12
and treatment cart logs to ensure the EMRBs and treatment
carts are regularly inventoried, sealed, and meet the minimum
par level.
Transfers
•
Nursing leadership should develop and implement internal
auditing of staff to ensure complete and thorough assessments
for patients returning from hospitalizations.
•
Healthcare leadership should consider adjusting the initial
health screening form to add the symptom of fatigue for
tuberculosis (TB) symptom monitoring and screening.
Medication Management
•
Medical and nursing leadership should ensure that chronic
care, hospital discharge, and en route patients receive their
medications timely and without interruption.
Nursing Performance
•
Nursing leadership should determine the root cause of
challenges that prevent outpatient nurses from performing
complete assessments and implement remedial measures as
appropriate, including training of staff.
•
Nursing leadership should determine the causes that prevent
PBSP correctional treatment center (CTC) nurses from
performing complete assessments and proper wound care, and
implement remedial measures as appropriate, including
training of staff.
Provider Performance
•
Medical leadership should consider reminding providers to
carefully review charts before rescheduling appointments due
to COVID-19 Interim Guidelines.12
•
Medical leadership should remind providers to document their
rationale for not following specialists’ recommendations.
Specialized Medical Housing
•
Nursing leadership should remind CTC nurses to ensure
complete documentation of wound care assessments including
clinical appearance of the wound, surrounding tissue and
measurements.
12 https://cchcs.ca.gov/covid-19-interim-guidance/
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 13
•
Nursing leadership should provide additional training on
complete assessments including CCHCS policy on abnormal
vital signs.
•
PBSP leadership should formulate a plan to ensure handwritten
documents are collected and scanned into the patient’s chart in
a timely manner.
•
Nursing leadership should ensure that the initial assessments
are completed within the required timeframe as stated in
CCHCS policy.
Specialty Services
•
Medical leadership should ensure that the institution timely
receive and review the specialty reports.
•
Medical leadership should determine the root cause(s) of
challenges in the timely provision of specialty appointments
and implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 14
Access to Care
In this indicator, OIG inspectors evaluated the institution’s ability to
provide patients with timely clinical appointments. Our inspectors Overall
reviewed the scheduling and appointment timeliness for newly arrived Rating
patients, sick calls, and nurse follow-up appointments. We examined Adequate
referrals to primary care providers, provider follow-ups, and specialists. Case Review
Furthermore, we evaluated the follow-up appointments for patients Rating
who received specialty care or returned from an off-site hospitalization. Adequate
Compliance
Results Overview
Score
Adequate
PBSP provided good access to care in the context of the COVID-19
(79.7%)
pandemic. The comparison of PBSP’s performance in Cycle 6 with its
performance during Cycle 5 presented a unique challenge with respect
to the COVID-19 pandemic and its repercussions throughout the
correctional health care system. We considered specific concerns
affecting PBSP during the review period such as reducing unnecessary
appointments to minimize spread. However, it is imperative not to
reschedule or cancel appointments when patients clinically need to be
seen. The OIG case reviewers evaluated each case with the
understanding that these circumstances may have impacted patient
care. We did not consider postponed appointments to be deficiencies
insofar as the provider’s assessments met standards of care. However,
in some instances, providers postponed or canceled appointments when
patients should have been seen. This is discussed in the Provider
Performance indicator.
Access to providers was mixed in the outpatient setting and in specialty
services. PBSP provided excellent access to follow-up care after
hospitalizations and after TTA encounters, and provided excellent
access to CTC providers. PBSP provided good access to nurses and
acceptable access to care following specialty appointments. After
reviewing the case review and compliance results, we considered the
context of the pandemic, the ongoing outbreak during the review
period, and the clinical background of the cases. Ultimately, we rated
this indicator as adequate.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 15
Case Review and Compliance Testing Results
We reviewed 140 provider, nursing, specialty, and hospital events that
required the institution to generate appointments. We identified eight
deficiencies relating to Access to Care, four of which were significant.13
Access to Clinic Providers
PBSP had mixed performance providing access to provider-ordered
follow-up appointments. Case review clinicians found no deficiencies in
the scheduling of provider appointments, while compliance testing
showed poor access to chronic care follow-up appointments (MIT 1.001,
58.3%) and nursing to primary care provider sick call referrals (MIT
1.005, 72.7%). The differing results found by case review compared to
compliance testing is attributed to case review clinicians taking into
account that appointments were rescheduled due to the interim
COVID-19 guidelines.14 While in some instances the provider should
have seen the patient, it was appropriate for other appointments to be
rescheduled during the pandemic to minimize COVID-19 transmission.
The instances in which we felt the patient should have been seen are
discussed in the Provider Performance indicator, as it was the
provider’s decision to reschedule the patient.
Access to Specialized Medical Housing Providers
PBSP provided excellent access to specialized medical housing
providers. Providers performed admission histories and physicals
timely (MIT 13.002 90.0%). Case review clinicians did not find any
deficiencies in access to providers in the correctional treatment center
(CTC). The providers saw patients according to policy guidelines.
Access to Clinic Nurses
PBSP provided good access to RN sick call most of the time. Both case
review and compliance inspectors noted that nursing staff triaged sick
call requests the same day they were received (MIT 1.003, 100%).
Compliance inspectors identified that patients had a face-to-face
assessment within one business day of the sick call triage most of the
time (MIT 1.004, 93.3%). However, OIG clinicians reviewed several sick
calls that were canceled or rescheduled due to COVID-19 guidelines
and believe the patients should have been seen. Examples are described
in the cases below:
13 Access to Care deficiencies were found in cases 1, 6, 11, 12, 18, and 20. Significant
deficiencies occurred in cases 1, 18, and 20.
14 https://cchcs.ca.gov/covid-19-interim-guidance/
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 16
•
In case 18, a patient submitted a sick call request with
complaints of severe skin pain, red bumps on his back, clear
yellow drainage from under his arms, and creases on his arms
and behind his legs for three days. Even though the patient
documented he had yellow drainage, which could be a sign of
infection, the nurse who reviewed the sick call determined a
visit was not necessary. This was the third time within the past
month an appointment was deferred. Appointments for this
patient continued to be canceled and the patient was eventually
hospitalized with sepsis, cellulitis, and dehydration.
•
In case 1, a patient without a history of migraines or headaches
submitted a sick call request with a complaint of severe
headaches due to sunlight and bright lights. The nurse
reviewed the appointment, and deemed the request
nonessential. Two and a half months later, the patient
submitted another sick call request with complaint of
numbness to the right arm and the nurse requested an
appointment within one business day instead of the same day.
Before the patient could appear for the face-to-face
appointment, he was sent to the hospital with slurred speech,
asymmetrical gait, drooping to right side of the face, and right
extremity weakness. He was diagnosed with a hemorrhagic
stroke.
We reviewed events in which patients had provider-to-nurse referrals,
care manager referrals, and care coordinator referrals. These
appointments occurred as scheduled and we did not identify any delays
or deficiencies.
Access to Specialty Services
PBSP had mixed performance with access to specialty services as case
review clinicians did not assign deficiencies in cases where off-site
specialists canceled appointments or appointments were canceled due
to quarantine. Compliance testing revealed poor access to high-priority
specialty consults (MIT 14.001, 25.0%), medium-priority consults (MIT
14.004, 20.0%), and routine-priority consults (MIT 14.007, 66.7%).
Specialty follow-up appointment access after high-priority specialty
visits was also poor (MIT 14.003, 50.0%); however, provider follow-up
appointment access after medium and routine priority specialty visits
was acceptable (MIT 14.006, 85.7% and MIT 14.009, 80.0%).
Follow-Up After Specialty Services
PBSP providers followed up with patients after specialty appointments
(MIT 1.008, 87.5%). Case reviewers identified that in several cases,
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 17
specialty nurses appropriately messaged providers to ensure patients
received follow-up that the specialists recommended.
Follow-up After Hospitalization
PBSP provided excellent provider follow-ups after hospitalization;
neither case review nor compliance testing identified any deficiencies.
(MIT 1.007, 100%). Communication between nurses and providers
helped ensure that all recommendations regarding patient care were
followed.
Follow-Up After Urgent or Emergent Care (TTA)
PBSP followed up with patients after urgent or emergent care in the
TTA. Case review clinicians did not find any follow up access to care
deficiencies for patients who were evaluated in the TTA.
Follow-Up for Patients Transferring Into the Institution
PBSP had mixed performance providing follow-up appointments for
patients transferring into the institution. A fair percentage of newly
arrived patients were seen timely (MIT 1.002, 76.0%).
Clinician On-Site Inspection
Most deficiencies identified by case review clinicians were due to face-
to-face nursing appointments which were either rescheduled or did not
occur, related to COVID-19 guidelines. PBSP managers explained that
the deficiencies were due to interim COVID-19 guidelines to minimize
movement and reserve face-to-face encounters for urgent and emergent
care only. PBSP leadership assigned the supervising registered nurse
(SRN) II the role of reviewing all nursing appointment orders and
postponing any they deem nonessential. OIG clinicians evaluated
deficiencies in light of the challenges imposed by the COVID-19
pandemic and considered the remaining deficiencies to be instances in
which a patient with a postponed appointment needed to be seen much
sooner.
During our on-site visit, we were unable to tour facility A and B clinics,
as all quarantine and isolation patients were housed in these areas, and
facility B clinic was being utilized to monitor and treat COVID-19
positive patients. On the first day of the on-site visit, no clinic lines
were being run because the entire institution was undergoing mass
COVID testing. On the second day of the on-site visit, we were able to
tour the facility C and D clinics where patients were being seen. One
nurse advised they normally receive approximately nine sick call
requests per day and perform an average of five to six face-to-face
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 18
assessments daily. Due to nursing staffing shortages, clinic RNs were
redirected to assist in other areas of the institution. Staff reported that
facility C clinic typically had no backlog of patient visits. However, on
the day of our visit, they reported that they had backlog of patient visits,
which they attributed to a COVID-19 outbreak in the community and in
the institution.
On both days of our on-site visit, OIG clinicians remotely attended the
daily all-staff meetings, which were led by the CEO. After the roll call
noting that all clinical areas were present, staff were advised of
pertinent information such as areas in quarantine or isolation, any
patients on hunger strike, suspension of patient lines due to mass
testing, and suspension of the incoming transfer bus. The meetings
were short but very informative. We were also able to attend the
provider huddle led by the chief medical executive (CME). This meeting
covered information concerning COVID-positive patients, treatment
regimens, emergent transfers to a higher level of care, hospital returns,
and specialty appointments. On the second day, we monitored the C
yard huddle, which was extremely thorough and included information
regarding all aspects of the huddle script. There appeared to be good
communication from leadership and clinical staff concerning patient
care.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 19
Compliance Testing Results
Table 6. 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
14 10 1 58.3%
allowable interval or 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,
19 6 0 76.0%
was the patient seen by the clinician within the required time frame?
(1.002) *
Clinical appointments: Did a registered nurse review the patient’s
30 0 0 100%
request for service the same day it was received? (1.003) *
Clinical appointments: Did the registered nurse complete a face-to-
face visit within one business day after the CDCR Form 7362 was 28 2 0 93.3%
reviewed? (1.004) *
Clinical appointments: If the registered nurse determined a referral to
a primary care provider was necessary, was the patient seen within the
8 3 19 72.7%
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 0 0 30 NA
frame specified? (1.006) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment within the required time 2 0 0 100%
frame? (1.007) *
Specialty service follow-up appointments: Did the clinician follow-up
visits occur within required time frames? (1.008) * , † 7 1 26 87.5%
Clinical appointments: Do patients have a standardized process to
3 3 0 50.0%
obtain and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 79.7%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care
physician follow-up visits following specialty services. As a result, we tested MIT 1.008 only for high-
priority specialty services or when staff ordered follow-ups. The OIG continued to test the clinical
appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 20
Table 7. 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 NA NA NA NA
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 NA NA NA NA
days? (12.004) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time 9 1 0 90.0%
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior to
4/2019): Did the primary care provider complete the Subjective, Objective,
0 0 10 NA
Assessment, and Plan notes on the patient at the minimum intervals
required for the type of facility where the patient was treated?
(13.003) *
Did the patient receive the high-priority specialty service within?
14 calendar days of the primary care provider order or the Physician 1 3 0 25.0%
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 provider? 1 1 2 50.0%
(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 3 12 0 20.0%
Request 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 6 1 8 85.7%
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 10 5 0 66.7%
Request 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 provider? 4 1 10 80.0%
(14.009) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still had
State-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 21
Recommendations
•
Medical leadership should determine the root cause(s) of
challenges in the timely provision of chronic care follow-up
appointments with providers, nurse-to-provider referrals and
implement remedial measures as appropriate.
•
The department should provide clear policy guidance to
institutions regarding how to manage care during the
pandemic, including how to manage care for chronic care
patients whose appointments might be cancelled or delayed,
how to prioritize patient movement to ensure provider
appointments occur, how to properly close an appointment for
patients who only receive a medical chart review, and how to
balance the workload to ensure equitable distribution of patient
care among nursing and providers.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 22
Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s ability to
timely complete radiology, laboratory, and pathology tests. Our Overall
inspectors determined whether the institution properly retrieved the Rating
resultant reports and whether providers reviewed the results correctly. Adequate
In addition, in Cycle 6, we examined the institution’s ability to timely Case Review
complete and review immediate (stat) laboratory tests. Rating
Adequate
Results Overview
Compliance
Score
During this review period, PBSP performed well in completing and
Adequate
retrieving diagnostic tests. Due to COVID-19 testing, PBSP conducted
(82.2%)
four times the number of diagnostic tests it conducted in Cycle 5. Case
reviewers found good test completion and management of diagnostic
reports. Compliance testing showed untimely management of
pathology information and incomplete patient notification letters. After
considering the various aspects of diagnostic services, the OIG rated
this indicator adequate.
Case Review and Compliance Testing Results
We reviewed 391 diagnostic events and found six deficiencies, one of
which was significant. Of those six deficiencies, we found four related
to health information management and one pertained to the completion
of diagnostic tests.15
For health information management, we consider test reports that were
never retrieved or reviewed to be a problem as severe as tests that were
never performed.
Test Completion
PBSP’s performance in completing diagnostic tests was mixed.
Compliance testing found excellent radiology test completion (MIT
2.001, 100%) and poor laboratory test completion (MIT 2.004, 50.0%).
Case review clinicians found only one deficiency related to delayed
completion of a laboratory test.
Health Information Management
Management of diagnostic services is critical, as therapy and decision-
making rely on accurate and timely information. PBSP providers had
excellent performance reviewing radiology studies (MIT 2.002, 100%),
laboratory studies (MIT 2.005, 100%), and pathology reports (MIT 2.011,
15 Diagnostic deficiencies were found in cases 16, 17, 22, 45, and 47.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 23
100%). However, the institution needed improvement with retrieval of
pathology reports (MIT 2.010, 33.3%) and communication of pathology
results with patients (MIT 2.012, 66.7%). Case review clinicians
identified four deficiencies; two were related to delayed endorsements
and the other two were due to the provider not sending notification
letters to the patients.
Clinician On-Site Inspection
Case review clinicians interviewed leadership, supervisors, and
providers about diagnostic workflows and deficiencies. Diagnostic
supervisors indicated they have increased their oversight to ensure
diagnostic results are sent to providers for their endorsements.
The providers reported they had no issues with laboratory services or
radiology services, as diagnostic tests occurred timely, and providers
had access to the results. The providers were also aware they were
required to send notification letters to patients to inform them of the
diagnostic results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 24
Compliance Testing Results
Table 8. 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
10 0 0 100%
the radiology report within specified time frames? (2.002) *
Radiology: Did the ordering health care provider communicate the
results of the radiology study to the patient within specified time 9 1 0 90.0%
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
10 0 0 100%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the health care provider communicate the results of
10 0 0 100%
the laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and
NA NA NA NA
receive the results within the required time frames? (2.007) *
Laboratory: Did the provider acknowledge the STAT results, OR did
nursing staff notify the provider within the required time frames (2.008) NA NA NA NA
*
Laboratory: Did the health care provider endorse the STAT laboratory
NA NA NA NA
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within
1 2 0 33.3%
the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
3 0 0 100%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results of
the pathology study to the patient within specified time frames? 2 1 0 66.7%
(2.012)
Overall percentage (MIT 2): 82.2%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 25
Recommendations
The OIG does not have any specific recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 26
Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency
Overall
medical care. Our clinicians reviewed emergency medical services by
Rating
examining the timeliness and appropriateness of clinical decisions
Adequate
made during medical emergencies. Our evaluation included examining
the emergency medical response, cardiopulmonary resuscitation (CPR) Case Review
quality, triage and treatment area (TTA) care, provider performance, Rating
and nursing performance. Our clinicians also evaluated the Emergency Adequate
Medical Response Review Committee’s (EMRRC) ability to identify
Compliance
problems with its emergency services. The OIG assessed the Score
institution’s emergency services through case review only; we did not (N/A)
perform compliance testing for this indicator.
Results Overview
PBSP generally delivered good emergency care. Compared to Cycle 5,
OIG clinicians reviewed slightly fewer events but identified more
deficiencies. The prior cycle identified five significant deficiencies
while in Cycle 6, we only identified one significant deficiency. Providers
performed very well in providing emergency care. Staff provided timely
and appropriate care most of the time, but did not always document
accordingly. One area of concern was review of the emergency medical
response (EMR) audits when transferring patients to a higher level of
care. While the audits were completed timely, they did not identify
areas of performance improvement in approximately half of the cases.
More thorough audits would assist management in identifying
additional training opportunities for staff. Taking all aspects into
account, the OIG rated this indicator as adequate.
Case Review Results
We reviewed 20 urgent or emergent events and identified 16 emergency
care deficiencies, only one of which was considered significant.16
Emergency Medical Response
PBSP staff responded promptly to emergencies throughout the
institution. Medical and custody staff worked cohesively to initiate care,
activate EMS, and transfer patients to a higher level of care when
applicable. OIG clinicians did not identify any significant deficiencies
in PBSP’s emergency response.
16 Deficiencies in emergency services were identified in cases 1, 2, 3, 6, 16, 17, 18, and 20.
The only significant deficiency was identified in case 17.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 27
Cardiopulmonary Resuscitation Quality
PBSP performed well in this subindicator. The OIG clinicians reviewed
four cases that required cardiopulmonary resuscitation (CPR).17 Medical
personnel initiated CPR in three of the cases. Custody staff initiated
CPR when medical staff arrived on scene for the other case. The
patients were assessed, and appropriate interventions were initiated.
Staff utilized the automated external defibrillator (AED), assisted
ventilations, provided narcotic reversal medications, checked blood
sugar levels, and requested 9-1-1 without delay. The following case is an
example of appropriate emergency response and interventions:
•
In case 3, a patient had a seizure, which was witnessed by staff,
and fell to the ground. Five medical staff responded and
provided care. When the patient became pulseless, CPR was
initiated, and the AED was utilized. The patient received
electrical shocks and four doses of narcotic reversal medication.
Emergency medical services (EMS) arrived, received report, and
continued care. The patient’s pulse returned and the patient
ultimately survived a cardiac arrest.
Provider Performance
PBSP providers performed excellently in urgent, emergent, and after-
hours care. In the cases we reviewed, providers considered diagnoses
appropriately and sent patients to the hospital when necessary. They
documented contact by the TTA nurses and urgent co-consults. We did
not identify any provider deficiencies in emergent or urgent care.
Nursing Performance
PBSP nurses performed well most of the time for emergency events.
Patients housed in COVID-19 quarantine were seen in the B yard clinic
to prevent possible spread of the COVID-19 virus. Nursing staff
evaluated patients and obtained initial vital signs, which were relayed
to providers. Patients were usually monitored appropriately with the
exception of the case described below:
•
In case 17, a medical alarm was activated for a patient
complaining of abdominal pain with nausea and rectal
bleeding. Nursing staff responded and transported the patient
to the clinic. The patient presented with a rapid heart rate. A
nurse did not obtain orthostatic vital signs, nor did the nurse
recheck the vital signs during the entire two hours the patient
was at the clinic. The patient was seen by a provider, who
17 CPR was performed on patients in cases 3, 4, 5, and 6.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 28
consulted with the chief physician and surgeon, and ordered
that the patient transfer to a higher level of care.
Nursing Documentation
While nurses responded quickly and provided appropriate interventions
most of the time, nursing documentation was an area in need of
improvement. Frequently, PBSP nurses failed to document times for
emergent transfers to a higher level of care as required by policy, did
not document handoff reports to EMS or the off-site ER, and failed to
document patients’ conditions prior to transfer. We identified a lack of
documentation of medications provided during emergency events in the
medication administration record (MAR). Although documentation
deficiencies were the most commonly identified during urgent and
emergent events, these documentation deficiencies are considered
minor and did not significantly increase the risk of harm to patients.
Emergency Medical Response Review Committee
While the EMRRC met monthly and discussed pertinent findings
obtained from the EMR audits, in seven of the 14 audits we reviewed,
we identified missing or conflicting times and information, and poor
identification of deficiencies by supervisory staff.18 The OIG
compliance team found incomplete checklists, missing entries, and
missing time documentation (MIT 15.003, 25.0%).
Clinician On-Site Inspection
OIG clinicians toured the triage and treatment area (TTA) during our
on-site visit. The TTA has two bays. We were advised one bay is used
for emergent or urgent patients and the other is shared by the off-site
return nurse and specialty clinics. Staffing for the TTA includes an RN
rover who responds to all emergencies on the yards and an additional
TTA RN for all shifts. The nurses are notified via radio and respond to
emergency situations with a van equipped with a Stryker stretcher and
emergency response equipment. At PBSP, the pill line staff are first
responders. When the institution has simultaneous calls, additional
staff is pulled from the correctional treatment center (CTC) or specialty
clinic.
During normal business hours, PBSP has a designated provider for the
TTA and the provider-on-call is utilized after hours, on weekends, and
on holidays. TTA staff advised that there was never a problem reaching
18 Deficiencies in EMR audits were identified in cases 1, 2, 3, 6, 17, and 20.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 29
the CME or the CP&S. Nursing staff acknowledged that the director of
nursing (DON) was a great resource.
Recommendations
•
Nursing leadership should provide additional training to staff
for complete documentation of emergency medical events to
include all appropriate times, interventions provided, report to
EMS personnel, patient reassessments, and communication
with the providers.
•
The Emergency Medical Response Review Committee
(EMRRC) should more thoroughly review emergency response
events and accurately detail findings.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 30
Health Information Management
In this indicator, OIG inspectors evaluated the flow of health
information, a crucial link in high-quality medical care delivery. Our Overall
inspectors examined whether the institution retrieved and scanned Rating
Adequate
critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical
Case Review
record in a timely manner. Our inspectors also tested whether
Rating
clinicians adequately reviewed and endorsed those reports. In addition,
Proficient
our inspectors checked whether staff labeled and organized documents
in the medical record correctly. Compliance
Score
Results Overview Inadequate
(64.2%)
PBSP had a mixed performance in this indicator. Case review clinicians
identified excellent hospital discharge report performance and good
diagnostic, emergency, and specialty report performance. However,
compliance scores showed poor performance handling specialty reports
and scanning. Factoring the proficient case review score and the poor
compliance score, the OIG rated this indicator as adequate.
Case Review and Compliance Testing Results
Our case review team reviewed 950 events and found 9 deficiencies
related to health information management. Of these 9 deficiencies, one
was significant.19
Hospital Discharge Reports
We reviewed 12 off-site emergency department and hospital visits.
PBSP staff timely retrieved hospital records, scanned them into the
medical record, and reviewed them properly. Case review clinicians did
not identify any deficiencies related to hospital discharge reports.
While compliance testing showed excellent performance with retrieval
and scanning of hospital discharge reports (MIT 4.003, 100%), it also
showed the institution did not include a discharge summary in one of
the samples (MIT 4.005, 50.0%).
Specialty Reports
PBSP had poor compliance scores for handling specialty reports. PBSP
did not always scan specialty reports timely (MIT 4.002, 70.8%), and had
late retrieval of high-priority specialty reports (MIT 14.002, 50.0%), late
retrieval of medium priority specialty reports (MIT 14.005, 46.7%), and
19 Health information management deficiencies were identified in cases 10, 16, 17, 18, 21,
22, 45, and 47. A significant deficiency was found in case 18.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 31
late retrieval and endorsement by the provider of routine-priority
specialty reports (MIT 14.008, 26.7%). We also discuss these findings in
the Specialty Services indicator. Case reviewers did not encounter
many specialty consultations and there were only a few deficiencies.
The following is an example:
•
In case 18, a dermatology report was not sent to the provider for
review. As a result, the subsequent dermatology follow-up was
beyond the time frame the specialist recommended. During our
on-site inspection, health information management supervisors
acknowledged that a staff member should have sent the report
to the provider.
Diagnostic Reports
PBSP performed well in managing diagnostic reports. Compliance
testing showed excellent performance in timely reviewing pathology
reports (MIT 2.011, 100%), but poor communication of pathology results
(MIT 2.012, 66.7%). Case review found that providers generally reviewed
and endorsed diagnostic reports and sent notification letters to inform
patients timely. However, of the 396 events, we identified three
instances in which providers did not endorse the diagnostic results
within policy time frames. Please refer to the Diagnostic Services
indicator for further discussion.
Urgent and Emergent Records
OIG clinicians reviewed 43 emergency care events and found that PBSP
nurses performed well in recording these events. Providers recorded
their emergency care excellently in the TTA as well as during their role
as the provider-on-call. We did not identify any deficiencies pertaining
to urgent and emergent records. The Emergency Services indicator
provides additional details.
Scanning Performance
PBSP had mixed performance in this subindicator. Case review
clinicians found good scanning performance. However, compliance
testing was poor due to the mislabeling of patient letters as DDP-Scan
(MIT 4.004, zero); every sample was mislabeled.20
Clinician On-Site Inspection
We discussed health information management processes with PBSP
health information management supervisors, nurses, and providers.
20 DDP is Developmental Disability Program.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 32
Providers expressed that diagnostic and specialty reports were available
timely. Nursing documentation issues were due to paper charting
during EHRS downtime.
Compliance Testing Results
Table 9. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s
electronic health record within three calendar days of the encounter 20 0 10 100%
date? (4.001)
Are specialty documents scanned into the patient’s electronic health
17 7 10 70.8%
record 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 1 0 1 100%
hospital discharge? (4.003) *
During the inspection, were medical records properly scanned,
0 24 0 0
labeled, 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
1 1 0 50.0%
and did a provider review the report within five calendar days of
discharge? (4.005) *
Overall percentage (MIT 4): 64.2%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 33
Table 10. 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
10 0 0 100%
endorse the radiology report within specified time frames? (2.002) *
Laboratory: Did the health care provider review and endorse the
10 0 0 100%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the provider acknowledge the STAT results, OR did
NA NA NA NA
nursing staff notify the provider within the required time frames?
(2.008) *
Pathology: Did the institution receive the final pathology report
1 2 0 33.3%
within the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
3 0 0 100%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results of
2 1 0 66.7%
the 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 2 2 0 50.0%
required time frame? (14.002) *
Did the institution receive and did the primary care provider review
the medium-priority specialty service consultant report within the 7 8 0 46.7%
required time frame? (14.005) *
Did the institution receive and did the primary care provider review
the routine-priority specialty service consultant report within the 4 11 0 26.7%
required time frame? (14.008) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Recommendations
•
The department should consider adjusting the default drop-
down menu on the results letter in the EHRS so that the menu
defaults to patient letter instead of DDP-Scan; the department
should train providers to generate the results letters
appropriately.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 34
Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting
areas, infection control, sanitation procedures, medical supplies, Overall
equipment management, and examination rooms. Inspectors also tested Rating
clinics’ ability to maintain auditory and visual privacy for clinical Inadequate
encounters. Compliance inspectors asked the institution’s health care
administrators to comment on their facility’s infrastructure and its Case Review
ability to support health care operations. The OIG rated this indicator Rating
(N/A)
solely on the compliance score, using the same scoring thresholds as in
the Cycle 4 and Cycle 5 medical inspections. Our case review clinicians
Compliance
do not rate this indicator.
Score
Inadequate
Results Overview
(67.9%)
PBSP’s health care environment performance decreased when
compared to its Cycle 5 inspection. Various PBSP aspects of the
institution’s health care environment still needed improvement:
multiple clinics contained expired medical supplies, inventories were
not performed for emergency medical response bags (EMRBs), and
EMRB logs were missing staff verification. These factors resulted in an
inadequate rating for this indicator.
Compliance Testing Results
Outdoor Waiting Areas
We examined outdoor patient waiting areas (see Photo 1). Health care
and custody staff reported existing waiting areas had sufficient seating
capacity. Staff reported the outdoor waiting area is only utilized when
the indoor waiting area is at capacity. Staff also reported they only call
patients close to their appointment time during inclement weather.
Photo 1: B clinic outdoor waiting area (photographed June 8, 2021)
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 35
Indoor Waiting Areas
We inspected indoor waiting areas (see Photo 2). Health care and
custody staff reported existing waiting areas contained sufficient
seating capacity. During our inspection, we did not observe
overcrowding or noncompliance with social distancing requirements in
any of the clinics’ indoor waiting areas.
Photo 2: B Clinic indoor waiting area (photographed June 8, 2021)
Clinic Environment
All clinic environments were sufficiently conducive for medical care;
they provided reasonable auditory privacy, appropriate waiting areas,
wheelchair accessibility, and nonexamination room workspace (MIT
5.109, 100%).
Of the 10 clinics we observed, seven contained appropriate space,
configuration, supplies, and equipment to allow their clinicians to
perform proper clinical examinations (MIT 5.110, 70.0%). In two clinics,
the examination room table had torn covers and one of the two clinics
also had a torn pillow cover used for physical therapy services (see
Photos 3 and 4). The remaining clinic did not allow patients to lie fully
extended on the examination table without obstruction (see Photo 5).
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 36
Photo 3: Torn examination room table cover (photographed June 8, 2021)
Photo 4: Torn pillow cover used for Physical Therapy services (photographed June 8, 2021)
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 37
Photo 5: Examination room configuration did not allow patients to lie fully extended without obstruction
(photographed June 10, 2021)
Clinic Supplies
Five of the 10 clinics followed adequate medical supply storage and
management protocols (MIT 5.107, 50.0%). We found one or more of the
following deficiencies in five clinics: expired medical supplies (see
Photo 6), unlabeled medical supplies (see Photo 7), staff members’
personal food stored with medical supplies, and compromised sterile
medical supply packaging.
Photo 6: Expired medical supply dated August 1, 2020 (photographed June 8, 2021)
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 38
Photo 7: Unlabeled medical supplies (photographed June 9, 2021)
Nine of the eleven clinics met the requirements for essential core
medical equipment and supplies (MIT 5.108, 81.8%). The correctional
treatment center (CTC) lacked a Snellen chart. CTC staff reported
patients are sent to the triage and treatment area (TTA) for eye
examinations. In another clinic, we found a nonfunctional oto-
opthalmoscope.
We examined emergency medical response bags (EMRBs) to determine
whether they contained all essential items. We checked whether staff
inspected the bags daily and inventoried them monthly. None of the
nine EMRBs passed our test (MIT 5.111, zero). We found one or both of
the following deficiencies with all EMRBs: staff failed to ensure EMRB
compartments were sealed and intact, and staff had not inventoried the
EMRBs when seal tags were replaced. In addition, the treatment carts
in the TTA and CTC did not meet the minimum inventory level and
lacked documentation indicating reasonable substitutions were made.
Medical Supply Management
All the medical supply storage areas located outside the medical clinics
stored medical supplies adequately. However, we found staff’s personal
food items stored in the pharmacy’s designated refrigerator and freezer
located in the receiving warehouse. In addition, staff did not record the
refrigerator and freezer temperatures. These deficiencies resulted in a
score of zero for this test (MIT 5.106).
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 39
According to the chief executive officer, PBSP did not have any concern
about the medical supplies process. Health care managers and medical
warehouse managers expressed no concern about the medical supply
chain or their communication process with the existing system in place.
Infection Control and Sanitation
Staff appropriately disinfected, cleaned, and sanitized eight of 11 clinics
(MIT 5.101, 72.7%). In one clinic, cleaning logs were not maintained. In
two clinics, we found that either the stretcher was unsanitary or the
exhaust under the clinic sink had accumulated dust (see Photo 8).
Photo 8: Exhaust under the clinic sink had accumulated dust (photographed June 8, 2021)
Staff in nine of 10 clinics (MIT 5.102, 90.0%) properly sterilized or
disinfected medical equipment. In one clinic, staff did not date stamp
and initial the packaging of sterilized medical equipment. We found
operating sinks and hand hygiene supplies in the examination rooms in
nine of 11 clinics (MIT 5.103, 81.8%). The patient restrooms in two
clinics lacked antiseptic soap, disposable hand towels, or both
antiseptic soap and disposable hand towels.
We observed patient encounters in five clinics. Health care staff in all
clinics adhered to universal hand hygiene precautions (MIT 5.104,
100%). Health care staff in all clinics followed proper protocols to
mitigate exposure to bloodborne pathogens and contaminated waste
(MIT 5.105, 100%).
Physical Infrastructure
PBSP’s health care management and plant operations manager reported
infrastructures in all clinical areas were in good working order and did
not hinder health care services.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 40
At the time of our medical inspection, the institution reported the
Health Care Facility Improvement Program (HCFIP) project was in
progress and included the renovation of Facility C primary clinic that
started April 26, 2021. The institution estimated the project would be
completed by April 2022. In addition, the renovation of the Clinic D
medication distribution room was still in the planning phase (MIT
5.999).
Table 11. Health Care Environment
Scored Answer
Compliance Questions
Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately
8 3 0 72.7%
disinfected, cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable
invasive and noninvasive medical equipment is properly sterilized or 9 1 1 90.0%
disinfected as warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks
9 2 0 81.8%
and sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal
5 0 6 100%
hand hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to
10 0 1 100%
blood-borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the
medical supply management process adequately support the needs 0 1 0 0
of the medical health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for
5 5 1 50.0%
managing and storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have
9 2 0 81.8%
essential core medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas
11 0 0 100%
conducive to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms
7 3 1 70.0%
conducive to providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency
crash carts inspected and inventoried within required time frames, 0 9 2 0
and do they contain essential items? (5.111)
Does the institution’s health care management believe that all clinical This is a nonscored test. Please
areas have physical plant infrastructures that are sufficient to provide see the indicator for discussion
adequate health care services? (5.999) of this test.
Overall percentage (MIT 5): 67.9%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 41
Recommendations
•
Nursing leadership should consider performing random spot
checks to ensure staff follow medical supply management
protocols.
•
Nursing leadership should direct each clinic nurse supervisor
to review the monthly emergency medical response bag (EMRB)
and treatment cart logs to ensure the EMRBs and treatment
carts are regularly inventoried, sealed, and met the minimum
par level.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 42
Transfers
In this indicator, OIG inspectors examined the transfer process for
Overall
those patients who transferred into the institution, as well as for those
Rating
who transferred to other institutions. For newly arrived patients, our
Adequate
inspectors assessed the quality of health screenings and the continuity
of provider appointments, specialist referrals, diagnostic tests, and
Case Review
medications. For patients who transferred out of the institution,
Adequate
inspectors checked whether staff reviewed patient medical records and
determined the patient’s need for medical holds. They also assessed if
staff transferred patients with their medical equipment and gave Compliance
Score
correct medications before patients left. In addition, our inspectors
Adequate
evaluated the ability of staff to communicate vital health transfer
(77.1%)
information, such as preexisting health conditions, pending
appointments, tests, and specialty referrals; and inspectors confirmed if
staff sent complete medication transfer packages to the receiving
institution. For patients who returned from off-site hospitals or
emergency rooms, inspectors reviewed whether staff appropriately
implemented the recommended treatment plans, administered
necessary medications, and scheduled appropriate follow-up
appointments.
Results Overview
PBSP performed well in this indicator. Compared to Cycle 5, OIG
clinicians reviewed more events and identified almost twice as many
deficiencies, although none were significant. While PBSP performed
proficiently for the transfer-out process, there was room for
improvement in the transfer-in and hospitalization-return processes.
Both case review and compliance testing had similar results, and the
overall rating was adequate.
Case Review and Compliance Testing Results
We reviewed 35 events in 13 cases in which patients transferred into or
out of the institution or returned from an off-site hospital or emergency
room. We identified seven deficiencies, none of which were
significant.21
Transfers In
PBSP’s transfer-in process had mixed performance. OIG clinicians
reviewed nine events in four cases in which patients transferred into
21 Deficiencies were identified in cases 5, 17, 18, 20, 23, and 47.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 43
the facility from other institutions. We identified only two minor
deficiencies:22
•
In case 5, an R&R nurse did not recognize a patient was a
diabetic and did not check the patient’s blood sugar.
•
In case 23, a patient arrived to PBSP with his medication but
did not receive his evening dose.
Our cases reviewers found nurses generally performed complete initial
assessments. However, the case review findings differed from the
compliance rating (MIT 6.001, 24.0%). The low compliance score was
almost entirely due to staff’s failure to ask patients during tuberculosis
screenings whether they experienced fatigue.
Similarly, our case reviewers PBSP staff usually ensured medication
continuity. This medication continuity findings were also reflected in
compliance testing for patients who arrived at the institution (MIT
6.003, 84.2%).
Case review did not identify problems with provider assess or access to
high-priority specialty services ordered by the provider upon patients’
arrival to PBSP. In compliance findings, although patients were
generally seen by the clinician within the required time frame (MIT
1.002, 76.0%), the patients often did not receive specialty services that
were ordered by the provider within 14 days (MIT 14.001, 25.0%).
Transfers Out
R&R nurses performed very well in managing medications for patients
who transferred out of the institution. There were no identifiable case
review deficiencies, which mirrors the Cycle 5 findings. In the cases we
reviewed, we found that proper screenings, which include vitals and
COVID-19 testing, were conducted. Additionally, we found that
patients were transferred out with all durable medical equipment and
medications. This correlates with compliance testing in that all patients
were transferred with their required medications and documents (MIT
6.101, 100%).
Hospitalizations
Patients returning from an off-site hospitalization or emergency room
are at high-risk for lapses in care quality. These patients typically
experienced severe illness or injury. They require more care and place
strain on the institution’s resources. Also, because these patients have
22 Transfer-in events occurred in cases 5, 18, 23, and 24. Deficiencies were identified in
cases 5 and 23.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 44
complex medical issues, the successful transfer of health information is
necessary for good quality care. Any lapses can result in serious
consequences for these patients.
OIG clinicians reviewed 24 events in nine cases in which patients
returned from an off-site hospitalization or emergency room visit. We
identified five deficiencies, none of which were significant.23 While
PBSP provided good care, there is opportunity for improvement in this
area. Most of the deficiencies we identified related to incomplete
assessments and nurses’ failure to identify and recheck abnormal vital
signs when patients returned to the institution. This can be
problematic, as providers rely on information gleaned from nursing
staff to make decisions regarding orders and housing. We did not
identify any deficiencies with primary care provider follow-up
appointments, a finding that coincided with compliance findings (MIT
1.007, 100%). Neither case review nor compliance testing revealed any
deficiencies pertaining to the availability of hospital or emergency
room summary reports (MIT 4.003, 100%). However, compliance testing
noted providers did not always review reports within five calendar days
of a patient’s discharge (MIT 4.005, 50.0%). Compliance testing also
identified that the continuity of hospital recommended medications
was inconsistent (MIT 7.003, 50.0%). Case reviewers, however, did not
find any clinically relevant medication issues after a patient’s hospital
discharge, or any issues in the timeliness of providers’ review of
hospital records.
Clinician On-Site Inspection
During the on-site inspection, OIG clinicians toured the clean and well-
organized receiving and release (R&R) area. There were three interview
rooms; one of those rooms was equipped as an exam room, and patient
scales were placed in the hallway outside the rooms. The RN assigned
to the R&R advised us this area had recently been updated. Pertinent
policy information, including abnormal vital signs, was displayed in
plastic covers for reference. The R&R nurse advised us the facility had
recently hired an RN for third watch. Before the addition to the third
watch post, a nurse would arrive early to prepare patients for
transferring out and would stay late to process patients transferring
into the facility. OIG clinicians were advised that licensed correctional
clinic (LCC) automated drug delivery system medications were recently
made available in the R&R. Before implementation of the LCC
medications, the rover RN was notified when patients needed
medications and would obtain them from the pharmacy or Omnicell.
23 Hospitalization or emergency room returns were reviewed in cases 1, 2, 5, 16, 17, 18, 19,
20, and 47. Deficiencies were identified in cases 17, 18, 20, and 47.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 45
When patients arrived at the facility during regular weekday hours, a
designated provider reconciled charts and placed orders, and after
hours the RN utilized the provider-on-call (POC). The RN we
interviewed appeared proficient in the transfer-in and transfer-out
processes and was able to answer questions concerning policy and local
operating procedures with ease.
During the on-site visit, medical leadership reported that there was a
COVID-19 outbreak in the community with a significant number of
hospital admissions, and that the bus that was to arrive with patients
transferring into the institution had been placed on hold.
Compliance Testing Results
Table 12. Transfers
Scored Answers
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: Did nursing staff complete the initial health screening and
6 19 0 24.0%
answer all screening questions within the required time frame?
(6.001) *
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
disposition section of the initial health screening form; refer the 17 0 8 100%
patient to the TTA if TB signs and symptoms were present; and
sign and date the form on the same day staff completed the health
screening? (6.002)
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
16 3 6 84.2%
were medications 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 6 0 0 100%
transfer packet required documents? (6.101) *
Overall percentage (MIT 6): 77.1%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 46
Table 13. 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 19 6 0 76.0%
patient seen by the clinician within the required time frame? (1.002) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment with a primary care provider 2 0 0 100%
within the required time frame? (1.007) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of hospital 1 0 1 100%
discharge? (4.003) *
For patients discharged from a community hospital: Did the preliminary
or final hospital discharge report include key elements and did a
1 1 0 50.0%
provider 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 1 1 0 50.0%
patient within required time frames? (7.003) *
Upon the patient’s transfer from one housing unit to another: Were
19 6 0 76.0%
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 1 3 0 25.0%
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 2 0 0 100%
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Recommendations
•
Nursing leadership should develop and implement internal
auditing of staff to ensure complete and thorough assessments
for patients returning from hospitalizations.
•
Healthcare leadership should consider adjusting the initial
health screening form to add the symptom of fatigue for TB
symptom monitoring and screening.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 47
Medication Management
In this indicator, OIG inspectors evaluated the institution’s ability to
administer prescription medications on time and without interruption. Overall
The inspectors examined this process from the time a provider Rating
prescribed medication until the nurse administered the medication to Inadequate
the patient. When rating this indicator, the OIG strongly considered
the compliance test results, which tested medication processes to a Case Review
Rating
much greater degree than case review testing. In addition to examining
Proficient
medication administration, our compliance inspectors also tested many
other processes, including medication handling, storage, error
Compliance
reporting, and other pharmacy processes.
Score
Inadequate
Results Overview
(64.4%)
PBSP had mixed performance in this indicator. Although case review
clinicians did not find many deficiencies in medication management,
compliance testing showed PBSP had difficulty distributing chronic
care medications, hospital discharge medications, and transfer
medications timely. Most of the deficiencies were due to delays in
medication administration. Factoring both case review and compliance
results, we rated the Medication Management indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 125 events in 26 cases related to medication management
and found five deficiencies, none of which were significant.24
New Medication Prescriptions
Both compliance and case review found PBSP performed well in
delivering new medication prescriptions most of the time. This
correlates with compliance testing (MIT 7.002, 92.0%). Case review
identified a minor deficiency in the following case:
•
In case 18, a patient did not receive his ordered medication,
prednisone timely. Prednisone was prescribed and filled on
three separate occasions. However, the prednisone was
administered one and two days late.
Chronic Medication Continuity
PBSP had mixed results in chronic medication continuity. Case review
clinicians identified only two minor deficiencies in patients receiving
their chronic care medications without interruption. Compliance
testing, however, found that PBSP performed poorly and identified that
24 Deficiencies in medication management were identified in cases 8, 15, and 18.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 48
patients usually received their chronic care medications one to two days
late (MIT 7.001, 5.9%). CCHCS policy states keep-on-person
medications must be available to patients one business day prior to
exhaustion.
Hospital Discharge Medications
Case review and compliance testing again showed different results.
Case review did not identify any medication management deficiencies
when patients returned from a hospitalization or emergency room visit.
However, the compliance team identified that half of the patients who
returned from a hospitalization did not receive their needed
medications within the required time frames (MIT 7.003, 50.0%). While
the institution performed better than in Cycle 5 for this test, the results
were still poor and showed room for improvement.
Specialized Medical Housing Medications
Both case review and compliance testing found PBSP performed well
most of the time in ensuring patients received their needed medications
upon admission to the correctional treatment center. This correlates
with compliance findings (MIT 13.004, 80.0%). OIG clinicians did not
identify any deficiencies when reviewing cases in which patients were
admitted to specialized medical housing.
Transfer Medications
PBSP performed well in ensuring patients who transferred into the
institution (MIT 6.003, 84.2%) and those who transferred from yard to
yard (MIT 7.005, 76.0%) received their medication timely.We found a
documentation discrepancy in one compliance sample. Specifically, we
found a nurse who documented medications that were not dispensed
due to patients’ refusal; however, in the comments section of the
medication administration record (MAR), this nurse documented there
was no time to dispense medication to a patient. This incongruent
documentation presents a serious question regarding medication
continuity.25
PBSP had mixed performance managing medications for patients who
were temporarily housed at the facility and had existing medication
orders. Compliance testing found that most patients sampled did not
receive their medications without interruption (MIT 7.006, 25.0%).
However, case review clinicians identified only one deficiency: a patient
25 Sample number 25, MIT 7.005.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 49
transferred into the institution with his medications and did not receive
his evening dose.
Both case review and compliance testing found PBSP performed
proficiently in ensuring all patients who transferred out of the
institution received a five-day supply of medications (MIT 6.101, 100%).
Additional information is discussed in the Transfers indicator.
Medication Administration
Case review and compliance evaluated the institution’s performance in
administering medications and monitoring patients taking
medications, specifically tuberculosis (TB) medications. In the 47 cases
the clinicians reviewed, we did not identify any patient receiving TB
medications.
PBSP did not have testable compliance samples for MITs 9.001 and
9.002.
Clinician On-Site Inspection
During the on-site visit, OIG clinicians met with the pharmacist and
toured the pill lines. The C yard pill line room was small, but clean and
well-organized. There were no keep-on-person (KOP) medications
pending delivery, and we were advised the pharmacy had yet to deliver
the medications for the day. The pill line staff advised that because no
patients housed in administrative segregation were classified with
mental health status, all of those patients were allowed to have KOP
medications in their cells. Staff reported that due to employee
shortages, there were a lot of mandates for nursing overtime. We were
also advised staff were redirected up to several times per shift.
In the receiving and release area, we observed where the licensed
correctional clinic (LCC) automated drug delivery system medications
were placed. As discussed in the Transfers indicator, these medications
had been made available the week before our visit and assisted the
nursing staff in providing continuity of medication administration for
patients who transferred in and out of the institution.
The OIG team monitored several huddles during the on-site visit and
identified there was good communication among each team regarding
medication management. Some issues discussed were medication
compliance, medications expiring within three days, parole
medications, suboxone, specialty medication for COVID-19 patients,
and upcoming expiring medication orders.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 50
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in
six of nine clinic and medication line locations (MIT 7.101, 66.7%). In
three locations, nurses could not describe the narcotic medication
discrepancy reporting process. In addition, in one of the three locations,
we observed the medication nurse remove narcotic medication from the
tackle box in a manner that does not allow spontaneous count.
PBSP appropriately stored and secured nonnarcotic medications in all
clinic and medication line locations (MIT 7.102, 100%).
Staff kept medications protected from physical, chemical, and
temperature contamination in seven of the 11 clinic and medication line
locations (MIT 7.103, 63.6%). In three locations, staff did not separate
the storage of oral and topical medications. In one location, nurses
stored return-to-pharmacy medications directly on the floor.
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 the multi-use medication as required by
CCHCS policy.
Nurses exercised proper hand hygiene and contamination control
protocols in four of seven locations (MIT 7.105, 57.1%). In three
locations, nurses neglected to wash or sanitize their hands before each
subsequent regloving.
Staff in five of seven medication preparation and administration areas
demonstrated appropriate administrative controls and protocols (MIT
7.106, 71.4%). In two locations, nurses did not maintain unissued
medication in its original, labeled packaging.
Staff in one of seven medication areas used appropriate administrative
controls and protocols when distributing medications to their patients
(MIT 7.107, 14.3%). In six clinics, medication nurses did not reliably
observe patients while they swallowed direct observation therapy
medications. In addition, in one of the six clinics, we observed a
medication nurse did not follow the CCHCS care guide when
administering Suboxone medication.
Pharmacy Protocols
PBSP followed general security, organization, and cleanliness
management protocols for nonrefrigerated and refrigerated
medications stored in its pharmacy (MIT 7.108, 7.109, and 7.110, 100%).
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 51
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 nurses present at the
time of the medication area inspection did not correctly complete
several medication area inspection checklists (CDCR form 7477). These
errors resulted in a score of zero for this test (MIT 7.111).
We examined eight medication error reports. The pharmacist-in-charge
timely and correctly processed all reports (MIT 7.112, 100%).
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 PBSP, 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. Fourteen of 16 applicable
patients interviewed indicated they had access to their rescue
medications. Two patients reported they did not have their prescribed
rescue inhaler. One patient stated he does not need the inhaler, while
the other patient stated the medication was taken away and placed in
the patient’s property when he transferred to the restricted housing
unit. We promptly notified the CEO of this concern, and health care
management obtained new refusal documentation for one patient, and
immediately issued a replacement rescue inhaler to the other patient
(MIT 7.999).
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Cycle 6, Pelican Bay State Prison 52
Compliance Testing Results
Table 14. Medication Management Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required
time frames or did the institution follow departmental policy for refusals or 1 16 8 5.9%
no-shows? (7.001) *
Did health care staff administer, make available, or deliver new order
prescription medications to the patient within the required time frames? (7.002) 23 2 0 92.0%
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 1 1 0 50.0%
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 NA NA NA NA
delivered to the patient within the required time frames? (7.004) *
Upon the patient’s transfer from one housing unit to another: Were
medications continued without interruption? (7.005) * 19 6 0 76.0%
For patients en route who lay over at the institution: If the temporarily housed
patient had an existing medication order, were medications administered or 1 3 0 25.0%
delivered without interruption? (7.006) *
All clinical and medication line storage areas for narcotic medications: Does
the institution employ strong medication security controls over narcotic 6 3 2 66.7%
medications 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 11 0 0 100%
assigned storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution keep nonnarcotic medication storage locations free of 7 4 0 63.6%
contamination in 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 8 3 0 72.7%
the assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ
and follow hand hygiene contamination control protocols during medication 4 3 4 57.1%
preparation and medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications 5 2 4 71.4%
for patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering 1 6 4 14.3%
medications to patients? (7.107)
Pharmacy: Does the institution employ and follow general security,
organization, and cleanliness management protocols in its main and remote 1 0 0 100%
pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
medications? (7.109) 1 0 0 100%
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
medications? (7.110) 1 0 0 100%
Pharmacy: Does the institution’s pharmacy properly account for narcotic
medications? (7.111) 0 1 0 0
Pharmacy: Does the institution follow key medication error reporting
protocols? (7.112) 8 0 0 100%
Pharmacy: For Information Purposes Only: During compliance testing, did the This is a nonscored test. Please
OIG find that medication errors were properly identified and reported by the see the indicator for discussion of
institution? (7.998) this test.
Pharmacy: For Information Purposes Only: Do patients in restricted This is a nonscored test. Please
housing units have immediate access to their KOP prescribed rescue see the indicator for discussion of
inhalers and nitroglycerin medications? (7.999) this test.
Overall percentage (MIT 7): 64.4%
* The OIG clinicians considered these compliance tests along with their case review findings when determining the
quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 15. Other Tests Related to Medication
Management
Scored Answer
Compliance Questions
Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
16 3 6 84.2%
were medications 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 6 0 0 100%
transfer-packet required documents? (6.101) *
Patients prescribed TB medication: Did the institution administer the
NA NA NA NA
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 NA NA NA NA
the medication? (9.002) *
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 8 2 0 80.0%
within required time frames? (13.004) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Recommendations
•
Medical and Nursing leadership should ensure that chronic
care, hospital discharge, and en route patients receive their
medications timely without interruption.
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Cycle 6, Pelican Bay State Prison 54
Preventive Services
In this indicator, OIG compliance inspectors tested whether the
Overall
institution offered or provided cancer screenings, tuberculosis (TB)
Rating
screenings, influenza vaccines, and other immunizations. If the
Adequate
department designated the institution as high risk for
coccidioidomycosis (valley fever), we tested the institution’s ability to Case Review
transfer patients out quickly. The OIG rated this indicator solely based Rating
(N/A)
on the compliance score, using the same scoring thresholds as in the
Cycle 4 and Cycle 5 medical inspections. Our case review clinicians do
Compliance
not rate this indicator. Score
Adequate
Results Overview (83.4%)
PBSP staff performed well in offering patients an influenza vaccine for
the most recent influenza season, as it offered colorectal cancer
screening for all patients ages 50 through 75, and required
immunizations to chronic care patients. However, they faltered in
screening patients annually for TB. These findings are set forth in the
table on the next page. We rated this indicator Adequate.
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Cycle 6, Pelican Bay State Prison 55
Compliance Testing Results
Table 16. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
NA NA NA NA
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 NA NA NA NA
the medication? (9.002) †
Annual TB screening: Was the patient screened for TB within the last
12 13 0 48.0%
year? (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 50 through the age of 75: Was the
25 0 0 100%
patient offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the
NA NA NA NA
patient offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was
NA NA NA NA
patient offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients?
12 2 11 85.7%
(9.008)
Are patients at the highest risk of coccidioidomycosis (valley fever)
NA NA NA NA
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 83.4%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† In April 2020, after our review but before this report was published, CCHCS reported adding the
symptom of fatigue into the EHRS PowerForm for tuberculosis symptom monitoring.
Source: The Office of the Inspector General medical inspection results.
Recommendations
The OIG offers no specific recommendations for this indicator.
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Cycle 6, Pelican Bay State Prison 56
Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care
Overall
delivered by the institution’s nurses, including registered nurses (RNs),
Rating
licensed vocational nurses (LVNs), psychiatric technicians (PTs), and
Adequate
certified nursing assistants (CNAs). Our clinicians evaluated nurses’
ability to make timely and appropriate assessments and interventions. Case Review
We also evaluated the institution’s nurses’ documentation for accuracy Rating
Adequate
and thoroughness. Clinicians reviewed nursing performance in many
clinical settings and processes, including sick call, outpatient care, care
Compliance
coordination and management, emergency services, specialized medical Score
housing, hospitalizations, transfers, specialty services, and medication (N/A)
management. The OIG assessed nursing care through case review only
and performed no compliance testing for this indicator.
When summarizing overall nursing performance, our clinicians
understand that nurses perform numerous aspects of medical care. As
such, specific nursing quality issues are discussed in other indicators,
such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Results Overview
PBSP generally delivered acceptable nursing care. Nursing staff
performed well in care management, emergency services, transfer
services, and specialty services. However, compared to Cycle 5, OIG
clinicians identified significantly more deficiencies with a notable
number related to COVID-19 nurse rounding and supervisory audits.
We identified challenges with registry staff’s performance of quarantine
and isolation rounds. Our clinicians identified opportunities for
improvement in several areas including documentation and
assessments. We rated PBSP Nursing Performance indicator as
adequate.
Case Review Results
We reviewed 182 nursing encounters in 41 cases. Of the nursing
encounters we reviewed, 102 were in the outpatient setting. We
identified 83 nursing performance deficiencies, 11 of which were
significant.26
26 Deficiencies in the quality of nursing care were identified in cases 1, 2, 3, 5, 6, 11, 12, 13,
15, 16, 17, 18, 19, 20, 23, 28, 29, 30, 31, 32, 35, 36, 37, 38, 39, 40, 41, 42, 45, 46, and 47.
Significant deficiencies were identified in cases 1, 6, 16, 17, 18, 36, 38, 41, and 47.
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Cycle 6, Pelican Bay State Prison 57
Nursing Assessment and Interventions
Most deficiencies related to the quality of nursing care provided at
PBSP were due to incomplete or inadequate nursing assessments.
During case review, OIG clinicians identified several emergency
response events in which nursing staff did not reassess or recheck vital
signs for patients who were sent to a higher level of care. We also
identified that nurses in both the inpatient and outpatient settings did
not follow CCHCS protocol for abnormal vitals and did not recheck
vital signs or notify the provider when patients had low heart rates,
high heart rates, or elevated blood pressures.27 Clinic nurses often did
not weigh patients during face-to-face assessments and, in several
cases, they did not thoroughly document when performing focused
assessments for specific complaints as described in the cases below.
•
In case 17, a patient submitted a sick call request stating he was
recently diagnosed with colitis and that, while he had been
taking antibiotics, the symptoms returned. He had abdominal
pain with bloody, tarry stool, weakness, and chills. The patient
was not evaluated the same day the sick call request was
triaged. When the patient was seen, the nurse did not fully
document an abdominal assessment.
•
In case 41, a patient submitted a sick call request with
complaints of having fatigue, dizziness, and chest tightness for
one week. The patient reported symptoms were intermittent
and began three weeks prior. While he had no symptoms at the
time of the evaluation, he was concerned about whether “his
heart was okay.” The nurse did not subjectively assess the
frequency, severity, and duration of the intermittent chest pain
and whether it occurred when the patient was active or at rest.
The nurse also did not subjectively assess the frequency and
duration of the patient’s dizziness and did not consider the
patient’s risk factors of high blood pressure, high cholesterol,
obesity, and recent COVID-19 infection.
While case review did not identify a pattern of deficiencies related to
interventions, the deficiencies we did identify were significant in the
following cases:
•
In case 1, a patient submitted a sick call request for a burning
sensation in the left calf. A nurse performed a face-to-face
evaluation and utilized nursing protocols to provide
acetaminophen from the OTC stock medications, even though
the patient’s electronic health record indicated the patient was
27 Abnormal vital signs were not rechecked and the provider was not notified in cases 6, 16,
17, 45, and 47.
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allergic to acetaminophen.28 Staff’s failure to review medication
allergies placed the patient at risk of harm.
•
In case 17, a patient complained of abdominal pain, weight loss
and bloody diarrhea. A clinic nurse evaluated the patient and
noted the patient had a fast heart rate. The nurse did not weigh
the patient or check the patient’s orthostatic vital signs. The
next day an emergency response was activated for the patient
due to abdominal pain and rectal bleeding. The first responder
noted the patient had a rapid heart rate. Again, a nurse did not
check orthostatic vital signs or weigh the patient. Nursing staff
did not recheck vital signs for over two hours before the patient
was sent to a higher level of care.
Nursing Documentation
In almost every area we reviewed, nursing documentation showed room
for improvement. Nurses frequently failed to document all times during
emergency responses, failed to document giving report to emergency
medical staff or to the emergency room, and often did not document
medication given in the medication administration record (MAR). We
identified deficiencies in face-to-face assessments, including
inconsistent documentation in the Infectious Disease section of the
assessment form that did not correlate with patient’s complaints. We
also found that the clinic nurses sometimes did not document exact
area or location of pain or injury. When performing quarantine and
isolation rounds, nursing staff often did not completely document vital
signs, complaints, or both vital signs and complaints. In the inpatient
correctional treatment center (CTC), nursing staff often failed to
document peripherally inserted central catheters (PICC) or wound care,
did not consistently document the percentage of meals patients
consumed, and intermittently failed to document the effectiveness of
PRN pain medication. While documentation deficiencies do not affect
patient care and are considered minor, this is an area in which PBSP
could improve.
Nursing Sick Call
Our clinicians reviewed 43 sick call requests and identified 24
deficiencies, seven of which were significant.29 Some of the significant
deficiencies were related to inadequate assessments and failure to
perform timely evaluations. Even when taking into consideration that,
due to COVID-19 guidelines, only urgent and emergent complaints
28 OTC means over the counter.
29 Deficiencies in face-to-face assessments for sick call requests were identified in cases 1,
5, 6, 17, 18, 20, 28, 29, 30, 31, 32, 35, 36, 37, 39, 40, 41, and 42. Significant deficiencies were
identified in cases 1, 6, 17, 18, 36, and 41.
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Cycle 6, Pelican Bay State Prison 59
were scheduled to be evaluated in person, we identified several
situations that warranted immediate attention. This is discussed further
and examples are cited in the Access to Care indicator.
Care Management
OIG clinicians reviewed four cases in which patients were evaluated by
a care manager.30 We were advised clinic RNs act as care managers and
clinic LVNs perform care coordinator duties, which include monthly
and yearly TB screenings, vital sign checks, and distribution of DME
and diabetic supplies. Case review did not identify any deficiencies in
scheduling or evaluating patients for care management appointments.
Wound Care
We reviewed two cases involving wound care orders. Both patients were
housed in the CTC.31 During case review, OIG clinicians identified
several days on which wound care was not provided or documented. We
also identified lack of documentation of PICC line care and dressing
changes.32 There are further discussed in the Specialized Medical
Housing indicator.
Emergency Services
PBSP performed well when responding to urgent and emergent
patients. While nurses initiated prompt and appropriate interventions,
their documentation was often incomplete, lacking timelines and
assessment information. Another area with room for improvement was
the accuracy of emergency response reviews completed as part of the
EMRRC audits. This is further discussed in the Emergency Services
indicator.
Hospital Returns
We reviewed 24 events in nine cases in which patients returned from an
off-site hospitalization or emergency room visit. We identified five
deficiencies, all related to nursing performance. All deficiencies were
due to either missing documentation or incomplete assessments; all
deficiencies were deemed minor, as they did not significantly affect
patient care. Please see the Transfers indicator for additional
information.
30 Patients were evaluated by the care manager in cases 5, 16, 23, and 24.
31 Wound care was ordered for cases 46 and 47.
32 PICC is a peripherally inserted central catheter.
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Cycle 6, Pelican Bay State Prison 60
Transfers
Most of the time, PBSP performed well in transferring patients in and
out of the institution. However, for patients who returned from
hospitalizations or emergency room visits, assessments were often
incomplete. We also identified that when patients presented with
abnormal vital signs, nurses did not recheck vitals or notify the provider
as CCHCS policy requires. Please refer to the Transfers indicator for
additional information.
Specialized Medical Housing
OIG clinicians examined 95 events that occurred within nine cases in
which patients were admitted to the correctional treatment center.33
Nurses provided adequate care, but we identified several incomplete
assessments, missing documentation, and failure to perform wound
care. This area offers opportunity for performance improvement and is
discussed in more detail in the Specialized Medical Housing indicator.
Specialty Services
We reviewed 28 events in 13 cases in which patients received specialty
services. In four cases, patients returned from a specialty procedure or
consultation. Nursing staff performed complete assessments, reviewed
discharge recommendations, and notified the provider. We only
identified one minor deficiency related to nursing performance.
Medication Management
OIG clinicians examined 125 events involving medication management
and identified five medication deficiencies, none of which were
significant. Nursing staff generally administered medications
appropriately, but we identified some instances in which nursing staff
did not properly document patient care in the medication
administration record (MAR). The Medication Management indicator
provides further information.
Clinician On-Site Inspection
Just before the OIG on-site visit, we were advised there was a COVID-
19 outbreak in the community and at the institution. On the first day of
our visit, during the all-staff meeting, we were advised all clinic lines
were interrupted, and nursing staff were redirected to assist with
testing the entire patient population for the virus. We were also advised
that the housing units on A and B yards were utilized for quarantine
33 Due to frequency of nursing contacts in the specialized medical housing, we bundle up to
two weeks of patient care into a single event.
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Cycle 6, Pelican Bay State Prison 61
and isolation. This hampered the OIG’s ability to interview clinic staff.
We were, however, able to interview nursing educators, the utilization
manager, the employee health nurse, the public health nurse, and
nursing staff in the TTA and CTC.
On the second day of the on-site visit, we were able to tour two of the
clinics. Staff informed us of multiple mandates and redirections due to
nursing shortages. OIG staff were advised nursing morale was low and
nursing staff were “tired.” During the compliance team’s on-site visit,
we were advised PBSP had a nursing shortage of about 60 percent.
During the case review on-site visit, we learned that about one and a
half to two years prior, PBSP lost six registered nurses (RN) and had not
recovered since. This was a drastic change from Cycle 5, when PBSP
only had a 17 percent nursing shortage. At the time of the on-site visit,
the institution had 14 positions filled with registry RNs and seven
positions filled with contract and registry LVNs. On the first day of the
visit, another experienced nurse was working a last shift before retiring.
The on-site response to the low staffing levels included the use of
registry staff to fill vacancies, and recruitments for civil service
candidates were continuous. We were also advised that PBSP evaluates
patient care activities daily and directs staffing resources to meet
workload demands.
The institution was also affected by the COVID-19 outbreak. During
our interview with the employee health nurse, the OIG team was
advised there were 57 active cases among staff and only 30 percent of
staff were vaccinated. On the first day of the OIG on-site visit, the
public health nurse advised the facility had 25 positive cases within the
incarcerated population, with 1,800 test results pending. During the
compliance visit, we were advised that 66 percent of the patient
population was vaccinated.
OIG clinicians were also able to meet with nursing instructors who
advised training was continuous given staff turnover, new nursing
registry, and mandatory trainings. The instructors reported difficulty
scheduling staff for all the required trainings due to nursing shortages
and the need to redirect staff. They also reported the annual skills
training consisted of only one to two hours of training and some of the
subjects covered included IVs, infectious disease, and hand hygiene.
The annual CTC training covered information on chronic care
conditions, IVs, chronic pain, and wound care. We were also advised
that some area supervisors also provide specific on-the-job training to
their staff, such as PICC line care for patients housed in the
correctional treatment center.
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Cycle 6, Pelican Bay State Prison 62
Recommendations
•
Nursing leadership should determine the root cause of
challenges that prevent outpatient nurses from performing
complete assessments and implement remedial measures as
appropriate, including training of staff.
•
Nursing leadership should determine the causes that prevent
PBSP CTC nurses from performing complete assessments and
proper wound care, and implement remedial measures as
appropriate, including training of staff.
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Cycle 6, Pelican Bay State Prison 63
Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of
Overall
care delivered by the institution’s providers: physicians, physician
Rating
assistants, and nurse practitioners. Our clinicians assessed the Adequate
institution’s providers’ ability to evaluate, diagnose, and manage their
patients properly. We examined provider performance across several Case Review
Rating
clinical settings and programs, including sick call, emergency services,
Adequate
outpatient care, chronic care, specialty services, intake, transfers,
hospitalizations, and specialized medical housing. We assessed Compliance
provider care through case review only and performed no compliance Score
(N/A)
testing for this indicator.
Results Overview
PBSP providers delivered satisfactory care to patients. However, some
providers rescheduled patients due to interim COVID-19 guidelines. In
certain situations, this increased the risk of patient harm. There were
also a few cases in which providers did not follow specialists’
recommendations and did not document the reasons. The COVID-19
pandemic provided context for our evaluation of providers’ care during
the review period. After extensive deliberation, we rated this indicator
as adequate.
Case Review Results
OIG clinicians reviewed 112 medical provider encounters and identified
21 deficiencies, 12 of which were significant.34 In addition, OIG
clinicians examined the quality of care in 20 comprehensive case
reviews. Of these 20 cases, 18 were rated adequate, and two were
inadequate.
Assessment and Decision-Making
PBSP providers appropriately assessed patients’ conditions and made
sound decisions. They generally asked concise questions and performed
proper documentation of patient histories. Providers formulated
reasonable differential diagnoses, ordered appropriate tests, and
referred patients when necessary. We found 11 deficiencies related to
providers’ decision-making.35
34 Provider performance deficiencies were found in cases 1, 7, 8, 9, 10, 11, 13, 16, 17, 18, 21,
and 46. Significant deficiencies were identified in cases 8, 10, 16, 17, 18, 21, and 46.
35 Decision-making deficiencies were found in cases 1, 7, 8, 9, 10, 11, 16, 17, and 18.
Significant deficiencies were found in cases 8, 16, 17, and 18.
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Cycle 6, Pelican Bay State Prison 64
We identified that certain providers tended to reschedule patients due
to COVID-19 interim guidelines. While this was acceptable for certain
episodic or chronic conditions, it was detrimental for others. The
following are examples:
•
In case 16, a provider canceled a chronic care appointment for a
patient with a history of high blood pressure and protein in his
urine. Protein in urine is an indication of kidney damage. It was
important to follow the patient as the blood pressure can cause
further kidney damage. The patient was eventually seen three
months later by a different provider.
•
In case 18, a provider canceled appointments and cited COVID-
19 as the reason for the appointment cancellation even though a
nurse repeatedly requested follow-up with the patient due to
the patient’s weeping eczema. The nurses eventually consulted
with another provider and the patient was admitted to the
hospital.
Review of Records
Generally, PBSP providers reviewed medical records carefully. We
found one deficiency in which a provider did not review the medication
record to identify that a patient had not taken his asthma medication
for months, and another deficiency in which a provider did not review
vital signs in a patient with a history of elevated blood pressure.
Emergency Care
PBSP providers managed patients with urgent and emergent conditions
exceptionally well in the TTA. On-site providers examined, diagnosed,
and triaged patients appropriately. We did not identify any problems in
providers’ communication with TTA RNs.
Chronic Care
During the review period, in most instances, PBSP providers
appropriately managed patients’ chronic health conditions; however, we
found two deficiencies related to blood pressure control and two related
to diabetes control. Several patients began Hepatitis C treatment. We
did not review any patients on anticoagulation.
Specialty Services
PBSP providers appropriately referred patients for specialty
consultation when needed. However, when specialists made
recommendations, providers did not always follow them and did not
document any reasons why. We found this in three of the cases we
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Cycle 6, Pelican Bay State Prison 65
reviewed. We discuss providers’ specialty performance further in the
Specialty Services indicator.
•
In case 46, a provider did not follow an infectious disease (ID)
specialist’s recommendation to change antibiotics, order
laboratory tests, and schedule further ID follow-up. The
provider did not document any reason why the
recommendations were not followed.
•
In case 16, a provider did not follow a cardiologist’s
recommendations for a nephrology consultation, to keep the
blood pressure below specific values, and to order a sleep study.
Documentation Quality
PBSP providers accurately documented encounters with patients and
communication with nurses. The chief medical executive even
documented when she had to contact a patient’s family for end-of-life
discussions. However, there were a few instances in which providers
did not accurately document information. In one case, a CTC discharge
summary did not include complete information. Another instance is
described below.
•
In case 11, a provider incorrectly documented that a patient,
who had a high blood pressure, had normal blood pressure on
the day of his visit.
Provider Continuity
Generally, PBSP offered good provider continuity. Providers were
assigned to specified clinics. When patients were moved into isolation,
placed in quarantine, or moved to the CTC, they were assigned a new
provider.
Clinician On-Site Inspection
At the time of our inspection, PBSP had an active COVID-19 outbreak.
In response, they conducted mass testing on the first day of our
inspection. Medical leadership also discussed how to improve
vaccination rates for their staff.
We attended daily provider huddles as well as team-based huddles. The
team huddles were well-run and included pertinent information and
discussion.
The providers we interviewed expressed they had full trust in the
executive and medical leadership team. One provider stated patients at
PBSP had better provider access than private sector patients. Medical
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Cycle 6, Pelican Bay State Prison 66
leadership was always available to listen and help with any concerns.
The providers stated that, due to the remoteness of the institution, they
sometimes approached care in a unique way. They had good working
relationships with nursing as well as custody staff. Providers mentioned
that nursing staff faced challenges due to staffing shortages. The
providers noted that nurses whom they worked with were very diligent
despite the staffing shortages.
Medical leadership stated they had a great group of providers, including
several advanced practitioners. They explained that a prior CEO was an
advanced practitioner who helped spearhead the use of advanced
practitioners in prison health care. Leadership utilized two
telemedicine providers and planned on utilizing more. They had no
problems with any of their providers. The CME helped contact families
when necessary. The CP&S helped approve patients to transfer out of
the isolation setting. Both the CME and CP&S were very involved with
day-to-day operations.
Recommendations
•
Medical leadership should consider reminding providers to
carefully review charts before rescheduling appointments due
to COVID-19 Interim Guidelines.36
•
Medical leadership should remind providers to document their
rationale for not following specialists’ recommendations.
36 https://cchcs.ca.gov/covid-19-interim-guidance/
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Cycle 6, Pelican Bay State Prison 67
Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the Overall
specialized medical housing units. We evaluated the performance of the Rating
medical staff in assessing, monitoring, and intervening for medically Adequate
complex patients requiring close medical supervision. Our inspectors
Case Review
also evaluated the timeliness and quality of provider and nursing intake
Rating
assessments and care plans. We assessed staff members’ performance in
Adequate
responding promptly when patients’ conditions deteriorated and looked
for good communication when staff consulted with one another while Compliance
Score
providing continuity of care. Our clinicians also interpreted relevant
Proficient
compliance results and incorporated them into this indicator. At the
(85.0%)
time of our inspection, PBSP’s specialized medical housing consisted of
the correctional treatment center (CTC).
Results Overview
PBSP provided acceptable care for patients housed in the CTC. In Cycle
5, case review clinicians identified only two deficiencies, none of which
were significant, which resulted in a proficient rating. However, in
Cycle 6, OIG clinicians identified 25 deficiencies, three of which were
significant. We discuss these significant deficiencies in the
subindicators below. After considering case review results and
compliance testing, we rated the Specialized Medical Housing
indicator as adequate.
Case Review and Compliance Testing Results
We reviewed nine CTC cases that included 28 provider events and 38
nursing events. Due to the volume of care that occurs in specialized
medical housing units, each provider and nursing event represents up
to one month of provider care and one week of nursing care,
respectively. We identified 25 deficiencies, three of which were
significant.37
Provider Performance
PBSP providers generally provided good care in the CTC. Case review
clinicians found that providers always performed admission histories
and physicals timely and rounded on patients in clinically appropriate
intervals. Compliance testing also showed that providers performed
admission histories and physicals timely (MIT 13.002, 90.0%). The
37 Specialized medical housing deficiencies were identified in cases 1, 17, 19, 45, 46, and 47.
Significant deficiencies were identified in cases 46 and 47.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 68
compliance team did not test for clinically appropriate intervals, as MIT
13.003 was not applicable.
In general, providers made sound decisions and documented
communication with patients and other staff. However, the following
are exceptions.
•
In case 46, a CTC provider saw a patient following an infectious
disease specialist consultation. The provider did not follow
through on the specialist’s recommendations to change
antibiotics or order laboratory tests, nor did the provider order
follow-up with the specialist.
•
In case 46, a CTC provider did not thoroughly document a
discharge summary. The provider did not relay that a patient
had a specialty consultation and was waiting for
transesophageal echocardiogram (TEE) results. By
happenstance, the patient did not have any adverse outcomes.38
Nursing Performance
Both case review and compliance testing concluded that patients
admitted to the CTC received timely initial health assessments most of
the time (MIT 13.001, 70.0%). We noted patients were assessed by
nursing staff every shift, but the assessments were often incomplete.
OIG clinicians concluded that of the 25 deficiencies identified in the
specialized medical housing cases, 21 were directly related to quality of
nursing care. Prominent areas of concern were incomplete assessments,
lack of documentation that wound care was provided, failure to recheck
abnormal vital signs, missing data, and failure to provide pertinent
interventions. An example is described below.
•
In case 47, a patient was admitted to the CTC for serratia
bacteremia, presumed endocarditis, epidural abscess, and
cervical disc fusion. Orders were written for IV antibiotics for
six weeks, wound care, and as-needed pain medication. During
our review of nursing care from December 11, 2020, through
December 31, 2020, nurses did not document assessing or
completing wound care from December 13, 2020, through
December 23, 2020, and did not provide pain intervention or
pain medication for moderate or severe pain for three different
assessments. This falls below clinical nursing standards.
However, the compliance team noted the CTC maintains an operational
call system to ensure patients have access to care (MIT 13.101, 100%).
38 The transesophageal echocardiogram test uses soundwaves to image the heart lining,
muscle, valves, and pumping function.
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Cycle 6, Pelican Bay State Prison 69
Medication Administration
Compliance testing found that patients admitted to the CTC received
their medications timely most of the time (MIT 13.004, 80.0%). Case
review did not find any issues in medication administration during our
review period for Cycle 6.
Clinician On-Site Inspection
The CTC has 20 beds, 10 designated for medical patients and 10
designated for mental health patients; all 20 beds have functional call
lights. They have two negative pressure rooms with ante rooms for
respiratory isolation. At the time of our on-site inspection, we were
advised only a few beds were available. The CTC was equipped with a
standard scale to weigh patients upon admission and as ordered, but we
were advised there was no wheelchair-accessible scale at the
institution.
During our on-site visit, we interviewed CTC nursing staff. Two
registered nurses and a psychiatric technician were on duty. One of the
RNs had been redirected to work in the CTC due to mass COVID-19
testing throughout the institution. The second RN was a registry RN
who had been working at the institution for only a few months. We
were advised there is usually a designated primary care provider for the
CTC during weekdays, and that staff contact the physician-on-call after
hours, on weekends, and on holidays. We met with the CTC provider,
who expressed great working relationships with nursing staff and
custody staff in the CTC.
OIG clinicians remotely attended the well-organized CTC daily huddle.
In attendance were medical providers such as the chief physician and
surgeon, and mental health providers such as the psychiatrist, the
psychologist, nursing staff, and the pharmacist. The director of nursing
(DON) was also in attendance as the supervising registered nurse II was
not on duty that day. Discussion included admissions, discharges,
emergencies, medication renewals, specialty appointments, and
treatments. The meeting started promptly and was both thorough and
concise.
When OIG clinicians met with nursing leadership to review on-site
questions concerning documentation missing from CTC cases, we were
advised the institution had no connectivity to the EHRS during a
specific time frame and that documentation was handwritten and
scanned into the chart. The missing documents were not provided to
the OIG.
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Compliance Testing Results
Table 17. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
7 3 0 70.0%
For OHU, CTC, and SNF: Prior to 4/2019: Did the registered
nurse complete an initial assessment of the patient on the day of
admission, or within eight hours of admission to CMF’s Hospice?
Effective 4/2019: Did the registered nurse complete an initial
assessment of the patient at the time of admission? (13.001) *
9 1 0 90.0%
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time
frame? (13.002) *
NA NA 10 NA
For OHU, CTC, SNF, and Hospice (applicable only for samples prior
to 4/2019): Did the primary care provider complete the Subjective,
Objective, Assessment, and Plan notes on the patient at the
minimum intervals required for the type of facility where the patient
was treated? (13.003) *, †
8 2 0 80.0%
Upon the patient’s admission to specialized medical housing: Were
all medications ordered, made available, and administered to the
patient within required time frames? (13.004) *
1 0 0 100%
For OHU and CTC only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells? (13.101) *
0 0 1 NA
For specialized health care housing (CTC, SNF, Hospice, OHU):
Do health care staff perform patient safety checks according to
institution’s local operating procedure or within the required time
frames? (13.102) *
Overall percentage (MIT 13): 85.0%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still have
State-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results
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Recommendations
•
Nursing leadership should remind CTC nurses to ensure
complete documentation of wound care assessments including
clinical appearance of the wound, surrounding tissue and
measurements.
•
Nursing leadership should provide additional training on
complete assessments including CCHCS policy on abnormal
vital signs.
•
Leadership should formulate a plan to ensure handwritten
documents are collected and scanned into the patient’s chart in
a timely manner.
•
Nursing leadership should ensure that the initial assessments
are completed within the required timeframe as stated in
CCHCS policy.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 72
Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty
Overall
services. The OIG clinicians focused on the institution’s ability to
Rating
provide needed specialty care. Our clinicians also examined specialty
appointment scheduling, providers’ specialty referrals, and medical Inadequate
staff’s retrieval, review, and implementation of any specialty
Case Review
recommendations.
Rating
Adequate
Results Overview
Compliance
PBSP provided poor specialty services. Although providers and nursing Score
Inadequate
staff performed competently, compliance testing for specialty access
(54.2%)
scored low. Case reviewers found that some providers did not always
follow specialists’ recommendations. Health information management
in this indicator is another area where case review found good
performance; however, compliance testing showed very poor retrieval of
health information. Because compliance testing showed uniformly poor
performance in specialty health information management, we rated
PBSP as inadequate for this indicator.
Case Review and Compliance Testing Results
We reviewed 28 events related to specialty services; 24 were specialty
consultations and procedures. We found seven deficiencies in this
category, four of which were significant.39
Access to Specialty Services
PBSP’s performance in this subindicator was mixed. Case review
clinicians did not find any deficiencies related to access to specialty
services. When providers requested specialty services, the appointments
occurred within the requested time frames. When delays were due to
cancellations by outside specialists, or when clinically stable patients
were rescheduled due to COVID-19 interim guidelines, we did not
assign deficiencies. However, compliance testing found untimely
appointments and poor access to specialty services with routine priority
(MIT 14.007, 66.7%) medium priority (MIT 14.004, 20.0%), and high
priority (MIT 14.001, 25.0%) referrals. PBSP performed excellently in
managing previously approved specialty appointments for newly
transferred patients (MIT 14.010,100%).
39 Specialty services deficiencies occurred in cases 6, 16, 18, 21, and 46. Significant
deficiencies were found in cases 16, 18, 21, and 46.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 73
Provider Performance
PBSP providers requested specialty consults correctly when they were
initially needed. However, providers did not always follow through with
specialists’ recommendations even though they were aware of them, as
evidenced by their endorsement of the reports. Compliance testing
showed that the institution followed up with patients in a timely
manner after specialty services (MIT 1.008, 87.5%).
Nursing Performance
Nurses at PBSP performed well in assessing patients who returned to
the facility from off-site specialty appointments. While nursing staff
appropriately obtained vital signs, assessed patients, and relayed off-
site recommendations to providers, we identified one minor deficiency
in which a patient had an abnormally low heart rate and a nurse did not
recheck the patient’s pulse or document notification to the provider.
Health Information Management
PBSP’s performance in managing specialty services health information
was mixed. Compliance testing showed poor retrieval and significant
difficulty obtaining provider review of routine-priority (MIT 14.008,
26.7%) medium-priority (MIT 14.005, 46.7%) and high-priority specialty
reports (MIT 14.002, 50.0%). Testing also showed untimely scanning of
specialty reports into the EHRS (MIT 4.002, 70.8%). Although case
review found fewer problems, there were still issues processing
specialty reports. The following is an example.
•
In case 18, a dermatology consultation was not sent to a
provider for review and, as a result, the subsequent dermatology
follow-up was delayed. On-site, the health information
management supervisor acknowledged the report was not sent
to the provider and stated the staff member will be assigned
training.
Clinician On-Site Inspection
We discussed specialty services with the specialty services supervisors.
They explained that due to COVID-19, they had a policy in which
providers or medical leadership would review pending appointments
and determine whether patients needed to be seen by the specialist as
originally ordered, or whether the appointment could be postponed.
During the review period, PBSP also experienced issues with
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Cycle 6, Pelican Bay State Prison 74
specialists’ availability in the community. eConsult was available to the
providers, and we observed one case in which it was utilized.40
OIG staff interviewed the utilization management (UM) RN who
advised that PBSP generates approximately 20 to 30 medical referrals
weekly. The UM RN reviews the chart and enters information into
InterQual.41 If a referral does not meet criteria, the UM RN discusses it
at the weekly provider meeting. The UM RN reiterated there was a
backlog of some specialty appointments due to the lack of specialist
appointment availability in the community. On-site specialty services
included optometry and physical therapy that did not require approval.
Orthotics and audiology, which do require referrals, were also available
on-site. In addition, CT scans, MRIs, ultrasounds, and FibroScans were
offered at the facility monthly, and appointments were scheduled by the
radiology staff.42 Due to the location of the institution and lack of close
off-site facilities for specialized procedures, the UM nurse advised
there had been instances of delays in transportation.
40eConsult is a web-based application that allows providers to consult with specialists for
advice and recommendations about patients’ medical conditions.
41 InterQual is an evidenced-based clinical support tool used to assist in determining
whether proposed services are clinically indicated and provided in the appropriate level, or
whether further evaluation is required.
42 A FibroScan is an imaging diagnostic test that evaluates for liver scarring and fatty
changes from liver disease.
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Cycle 6, Pelican Bay State Prison 75
Compliance Testing Results
Table 18. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
1 3 0 25.0%
Did the patient receive the high-priority specialty service within 14
calendar days of the primary care provider order or the Physician
Request for Service? (14.001) *
2 2 0 50.0%
Did the institution receive and did the primary care provider review
the high-priority specialty service consultant report within the
required time frame? (14.002) *
1 1 2 50.0%
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care
provider? (14.003) *
3 12 0 20.0%
Did the patient receive the medium-priority specialty service within
15-45 calendar days of the primary care provider order or Physician
Request for Service? (14.004) *
7 8 0 46.7%
Did the institution receive and did the primary care provider review
the medium-priority specialty service consultant report within the
required time frame? (14.005) *
6 1 8 85.7%
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary care
provider? (14.006) *
10 5 0 66.7%
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician
Request for Service? (14.007) *
4 11 0 26.7%
Did the institution receive and did the primary care provider review
the routine-priority specialty service consultant report within the
required time frame? (14.008) *
4 1 10 80.0%
Did the patient receive the subsequent follow-up to the routine-
priority specialty service appointment as ordered by the primary care
provider? (14.009) *
2 0 0 100%
For endorsed patients received from another CDCR institution: If the
patient was approved for a specialty services appointment at the
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
2 2 0 50.0%
Did the institution deny the primary care provider’s request for
specialty services within required time frames? (14.011)
2 2 0 50.0%
Following the denial of a request for specialty services, was the
patient informed of the denial within the required time frame?
(14.012)
Overall percentage (MIT 14): 54.2%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 19. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up
7 1 26 87.5%
visits occur within required time frames? (1.008) *, †
Are specialty documents scanned into the patient’s electronic health 17 7 10 70.8%
record within five calendar days of the encounter date? (4.002) *
* The OIG clinicians considered these compliance tests along with their own case review findings
when determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care
physician follow-up visits following most specialty services. As a result, we test 1.008 only for high-
priority specialty services or when the staff orders PCP or PC RN follow-ups. The OIG continues to test
the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
Recommendations
•
Medical leadership should ensure that the institution timely
receive and review the specialty reports.
•
Medical leadership should determine the root cause(s) of
challenges in the timely provision of specialty appointments
and implement remedial measures as appropriate.
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Cycle 6, Pelican Bay State Prison 77
Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care
administrative processes. Our inspectors examined the timeliness of the Overall
Rating
medical grievance process and checked whether the institution
Proficient
followed reporting requirements for adverse or sentinel events and
patient deaths. Inspectors checked whether the Emergency Medical
Case Review
Response Review Committee (EMRRC) met and reviewed incident Rating
packages. We reviewed and determined whether the institution (N/A)
conducted the required emergency response drills. Inspectors also
Compliance
assessed whether the Quality Management Committee (QMC) met
Score
regularly and addressed program performance adequately. In addition, Proficient
the inspectors examined if the institution provided training and job (86.5 %)
performance reviews for its employees. They checked whether staff
possessed current, valid professional licenses, certifications, and
credentials. The OIG rated this indicator solely based on the
compliance score, using the same scoring thresholds as in the Cycle 4
and Cycle 5 medical inspections. Our case review clinicians do not rate
this indicator.
Because none of the tests in this indicator affected clinical patient care
directly (it is a secondary indicator), the OIG did not consider this
indicator’s rating when determining the institution’s overall quality
rating.
Results Overview
PBSP performed well in this indicator. It scored high in most applicable
tests; however, a few areas had room for improvement. The EMMRC
had incomplete checklists and forms. In addition, PBSP did not
properly complete required forms during emergency medical response
drills. These findings are set forth in the table below. We rated this
indicator proficient.
Nonscored Results
We obtained CCHCS Death Review Committee (DRC) reporting data.
Three unexpected (Level 1) deaths occurred during our review period.
The DRC must complete its death review summary report within 60
calendar days of a death. When the DRC completes the death review
summary report, it must submit the report to the institution’s CEO
within seven calendar days of completion. In our inspection, we found
the DRC timely completed one death summary report and submitted
the report to the institution’s CEO timely. However, DRC did not
complete two death review reports promptly; the DRC finished these
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Cycle 6, Pelican Bay State Prison 78
two reports 45 and 104 days late, respectively, and submitted them to
the institution’s CEO 38 and 100 days after that (MIT 15.998).
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Cycle 6, Pelican Bay State Prison 79
Compliance Testing Results
Table 20. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
NA NA NA NA
For health care incidents requiring root cause analysis (RCA): Did the
institution meet RCA reporting requirements? (15.001)
6 0 0 100%
Did the institution’s Quality Management Committee (QMC) meet
monthly? (15.002)
3 9 0 25.0%
For Emergency Medical Response Review Committee (EMRRC)
reviewed cases: Did the EMRRC review the cases timely, and did
the incident packages the committee reviewed include the required
documents? (15.003)
4 0 0 100%
For institutions with licensed care facilities: Did the Local Governing
Body (LGB) or its equivalent meet quarterly and discuss local
operating procedures and any applicable policies? (15.004)
0 3 0 0
Did the institution conduct medical emergency response drills during
each watch of the most recent quarter, and did health care and
custody staff participate in those drills? (15.101)
10 0 0 100%
Did the responses to medical grievances address all of the inmates’
appealed issues? (15.102)
3 0 0 100%
Did the medical staff review and submit initial inmate death reports
to the CCHCS Death Review Unit on time? (15.103)
10 0 0 100%
Did nurse managers ensure the clinical competency of nurses who
administer medications? (15.104)
4 0 5 100%
Did physician managers complete provider clinical performance
appraisals timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 10 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR),
Basic Life Support (BLS), and Advanced Cardiac Life Support (ACLS) 2 0 1 100%
certifications? (15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy 6 0 1 100%
maintain a valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
1 0 0 100%
Agency (DEA) registration certificates? (15.109)
Did nurse managers ensure their newly hired nurses received the
1 0 0 100%
required onboarding and clinical competency training? (15.110)
This is a nonscored test. Please
Did the CCHCS Death Review Committee process death review
refer to the discussion in this
reports timely? (15.998)
indicator.
This is a nonscored test. Please
What was the institution’s health care staffing at the time of the OIG
refer to Table 4 for CCHCS-
medical inspection? (15.999)
provided staffing information.
Overall percentage (MIT 15): 86.5%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no specific recommendations for this indicator.
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Cycle 6, Pelican Bay State Prison 81
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 PBSP
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Cycle 6, Pelican Bay State Prison 82
Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the
recommendation of its stakeholders, which continues in the Cycle 6
medical inspections. Below, Table A–1 provides important definitions
that describe this process.
Table A–1. Case Review Definitions
Case, Sample, The medical care provided to one patient over a specific
or Patient period, which can comprise detailed or focused case reviews.
A review that includes all aspects of one patient’s medical care
Comprehensive assessed over a six-month period. This review allows the OIG
clinicians to examine many areas of health care delivery, such as
Case Review
access to care, diagnostic services, health information
management, and specialty services.
A review that focuses on one specific aspect of medical care.
Focused This review tends to concentrate on a singular facet of patient
Case Review care, such as the sick call process or the institution’s
emergency medical response.
A direct or indirect interaction between the patient and the
health care system. Examples of direct interactions include
Event provider encounters and nurse encounters. An example of an
indirect interaction includes a provider reviewing a diagnostic
test and placing additional orders.
Case Review A medical error in procedure or in clinical judgment. Both
procedural and clinical judgment errors can result in policy
Deficiency
noncompliance, elevated risk of patient harm, or both.
Adverse Event An event that caused harm to the patient.
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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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Cycle 6, Pelican Bay State Prison 84
Figure A–2. Case Review Testing
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Cycle 6, Pelican Bay State Prison 85
Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and
compliance inspectors. Analysts follow a detailed selection
methodology. For most compliance questions, we use sample sizes of
approximately 25 to 30. Figure A–3 below depicts the relationships and
activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT)
questions to determine the institution’s compliance with CCHCS
policies and procedures. Our nurse inspectors assign a Yes or a No
answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain
information, allowing them to answer most of the MIT questions. Our
regional nurses visit and inspect each institution. They interview health
care staff, observe medical processes, test the facilities and clinics,
review employee records, logs, medical grievances, death reports, and
other documents, and obtain information regarding plant infrastructure
and local operating procedures.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 86
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
To reach an overall quality rating, our inspectors collaborate and
examine all the inspection findings. We consider the case review, and
the compliance testing results for each indicator. After considering all
the findings, our inspectors reach consensus on an overall rating for the
institution.
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 87
Appendix B: Case Review Data
Table B–1. PBSP Case Review Sample Sets
Sample Set Total
CTC/OHU 3
Death Review/Sentinel Events 2
Diabetes 4
Emergency Services – CPR 2
Emergency Services – Non-CPR 2
High Risk 5
Hospitalization 5
Intra-system Transfers In 2
Intra-system Transfers Out 2
RN Sick Call 18
Specialty Services 2
Total 47
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 88
Table B–2. PBSP Case Review Chronic Care Diagnoses
Diagnosis Total
Anemia
3
Arthritis/Degenerative Joint Disease
2
Asthma
4
COPD
1
11
COVID-19
Cardiovascular Disease
1
Chronic Kidney Disease 2
Chronic Pain
7
Cirrhosis/End-Stage Liver Disease
1
Deep Venous Thrombosis/Pulmonary Embolism
1
Diabetes
7
Gastroesophageal Reflux Disease
3
Hepatitis C
9
Hyperlipidemia 9
Hypertension
15
Mental Health
4
Seizure Disorder
2
Sleep Apnea 9
Total 91
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 89
Table B–3. PBSP Case Review Events by Program
Diagnosis Total
Diagnostic Services
392
Emergency Care 43
Hospitalization
24
Intra-system Transfers-In 9
Intra-system Transfers-Out
2
Outpatient Care 351
Specialized Medical Housing 95
Specialty Services 34
Total 950
Table B–4. PBSP Case Review Sample Summary
MD Reviews Detailed 20
MD Reviews Focused 3
RN Reviews Detailed 15
RN Reviews Focused 24
Total Reviews 62
Total Unique Cases 47
Overlapping Reviews (MD & RN) 15
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 90
Appendix C. Compliance Sampling Methodology
Pelican Bay 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
Patients one 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 Appointment • Clinic (each clinic tested)
(6 per clinic) List • Appointment date (2–9 months)
• Randomize
MIT 1.007 Returns From 2 OIG Q: 4.005 • See Health Information
Community Management (Medical Records)
Hospital (returns from community hospital)
MIT 1.008 Specialty Services 34 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 0 Quest • Appt. date (90 days–9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.010–012 Pathology 3 InterQual • Appt. date (90 days–9 months)
• Service (pathology related)
• Randomize
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 91
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 34 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 2 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for any • Any misfiled or mislabeled
tested inmate document identified during
OIG compliance review (24 or
more = No)
MIT 4.005 Returns From 2 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
MITs 5.107–111 on-site review clinical 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 6 OIG inspector • R&R IP transfers with medication
on-site review
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 92
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 2 OIG Q: 4.005 • See Health Information
Community Hospital Management (Medical Records)
(returns from community hospital)
MIT 7.004 RC Arrivals— N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2–8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 4 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
Areas by test on-site review & med line areas that store
medications
MITs 7.104–107 Medication Varies OIG inspector • Identify and inspect on-site
Preparation and by test on-site review clinical areas that prepare and
Administration Areas administer medications
MITs 7.108–111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 8 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication
error reports (recent 12 months)
16
MIT 7.999 Restricted Unit On-site active • KOP rescue inhalers &
KOP Medications medication listing nitroglycerin medications for IPs
housed in restricted units
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 93
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 0 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
Annual Screening to inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior
Vaccinations to inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior
Screening to inspection)
• Date of birth (51 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior
institution to inspection)
• Date of birth (age 52–74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs.
institution prior to 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
0
Cocci transfer • Reports from past 2–8 months
status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 94
Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001–008 RC N/A at this SOMS • Arrival date (2–8 months)
institution • Arrived from (county jail, return
from parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001–004 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 4 Specialty Service • 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 Service • 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 14.007–009 Routine-Priority 15 Specialty Service • 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
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 95
MIT 14.010 Specialty Services 2 Specialty Service • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3–9 months)
• Randomize
MITs 14.011–012 Denials 4 InterQual • Review date (3–9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 96
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events (ASE) 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 3 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 4 On-site • All required performance
Evaluation Packets provider evaluation documents
evaluation files
MIT 15.106 Provider Licenses 10 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site • All staff
Response certification ◦ Providers (ACLS)
Certifications tracking logs ◦ 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
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 97
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.109 Pharmacy and All On-site listing • All DEA registrations
Providers’ Drug of 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
Death Review 3
OIG summary log: • Between 35 business days &
Committee deaths 12 months prior
• California Correctional
Health Care Services death
reviews
Office of the Inspector General, State of California Inspection Period: November 2020 – April 2021 Report Issued: March 2022
Cycle 6, Pelican Bay State Prison 98
California Correctional Health Care
Services’ Response
Office of the Inspector General, State of California Inspection Period: June 2020 – November 2021 Report Issued: March 2022
Cycle 6
Medical Inspection Report
for
Pelican Bay State Prison
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
STATE of CALIFORNIA
March 2022
OIG