OIG
Pleasant Valley State Prison Medical Inspection Results Cycle 5
Read the report at CDCR ↗
Roy W. Wesley Office of the Inspector General
Inspector General
Pleasant Valley State Prison
Medical Inspection Results
Cycle 5
April 2019
Fairness Integrity Respect
Medical Inspection Unit Page 1
Office of the Inspe ctSor Geenerral vice TransparencStyate of California
Office of the Inspector General
PLEASANT VALLEY STATE PRISON
Medical Inspection Results
Cycle 5
Roy W. Wesley
Inspector General
Bryan B. Beyer
Chief Deputy Inspector General
Shaun R. Spillane
Public Information Officer
April 2019
T C
ABLE OF ONTENTS
Foreword ............................................................................................................................................... i
Overall Rating: Inadequate ............................................................................................................. iii
Executive Summary ............................................................................................................................ iii
Expert Clinician Case Review Results....................................................................................... v
Compliance Testing Results...................................................................................................... vi
Recommendations .................................................................................................................... vii
Population-Based Metrics ....................................................................................................... viii
Introduction .......................................................................................................................................... 1
About the Institution ......................................................................................................................... 1
Objectives, Scope, and Methodology .................................................................................................. 4
Case Reviews .................................................................................................................................... 5
Patient Selection for Retrospective Case Reviews .................................................................... 6
Benefits and Limitations of Targeted Subpopulation Review ................................................... 7
Case Review Sampling Methodology ........................................................................................ 7
Breadth of Case Reviews ........................................................................................................... 8
Case Review Testing Methodology ........................................................................................... 9
Compliance Testing ........................................................................................................................ 12
Sampling Methods for Conducting Compliance Testing ......................................................... 12
Scoring of Compliance Testing Results ................................................................................... 12
Overall Quality Indicator Rating for Case Reviews and Compliance Testing ............................... 12
Population-Based Metrics............................................................................................................... 13
Medical Inspection Results ................................................................................................................ 14
Access to Care ................................................................................................................. 17
Case Review Results ................................................................................................................ 17
Compliance Testing Results..................................................................................................... 21
Diagnostic Services.......................................................................................................... 23
Case Review Results ................................................................................................................ 23
Compliance Testing Results..................................................................................................... 24
Emergency Services ......................................................................................................... 26
Case Review Results ................................................................................................................ 26
Health Information Management..................................................................................... 30
Case Review Results ................................................................................................................ 30
Compliance Testing Results..................................................................................................... 32
Health Care Environment ................................................................................................ 33
Compliance Testing Results..................................................................................................... 33
Inter- and Intra-System Transfers.................................................................................... 36
Case Review Results ................................................................................................................ 36
Compliance Testing Results..................................................................................................... 39
Pharmacy and Medication Management ......................................................................... 41
Case Review Results ................................................................................................................ 41
Compliance Testing Results..................................................................................................... 43
Prenatal and Post-Delivery Services ............................................................................... 47
Pleasant Valley State Prison, Cycle 5 Medical Inspection Table of Contents
Office of the Inspector General State of California
Preventive Services ......................................................................................................... 48
Compliance Testing Results..................................................................................................... 48
Quality of Nursing Performance .................................................................................... 50
Case Review Results ................................................................................................................ 50
Quality of Provider Performance .................................................................................. 54
Case Review Results ................................................................................................................ 54
Reception Center Arrivals ............................................................................................... 58
Specialized Medical Housing ......................................................................................... 59
Case Review Results ................................................................................................................ 59
Compliance Testing Results..................................................................................................... 60
Specialty Services ........................................................................................................... 62
Case Review Results ................................................................................................................ 62
Compliance Testing Results..................................................................................................... 64
Administrative Operations (Secondary)......................................................................... 66
Compliance Testing Results..................................................................................................... 66
Recommendations .............................................................................................................................. 69
Population-Based Metrics .................................................................................................................. 70
Methodology ............................................................................................................................ 70
Comparison of Population-Based Metrics ............................................................................... 70
Results of Population-Based Metric Comparison .................................................................... 71
Appendix A — Compliance Test Results .......................................................................................... 73
Appendix B — Clinical Data ............................................................................................................. 86
Appendix C — Compliance Sampling Methodology ........................................................................ 90
California Correctional Health Care Services’ Response .................................................................. 97
Pleasant Valley State Prison, Cycle 5 Medical Inspection Table of Contents
Office of the Inspector General State of California
L T F
IST OF ABLES AND IGURES
PVSP Executive Summary Table ....................................................................................................... iv
PVSP Health Care Staffing Resources as of November 2017 ............................................................ 2
PVSP Master Registry Data as of October 30, 2017 ........................................................................... 3
Exhibit 1. Case Review Definitions .................................................................................................... 5
Chart 1. Case Review Sample Selection ............................................................................................. 8
Chart 2. Case Review Testing and Deficiencies ............................................................................... 10
Chart 3. Inspection Indicator Review Distribution............................................................................ 14
PVSP Results Compared to State and National HEDIS Scores ........................................................ 72
Table B-1: PVSP Sample Sets ........................................................................................................... 86
Table B-2: PVSP Chronic Care Diagnoses ....................................................................................... 87
Table B-3: PVSP Event – Program ................................................................................................... 88
Table B-4: PVSP Review Sample Summary..................................................................................... 89
Pleasant Valley State Prison, Cycle 5 Medical Inspection List of Tables and Figures
Office of the Inspector General State of California
This page intentionally left blank.
Pleasant Valley State Prison, Cycle 5 Medical Inspection
Office of the Inspector General State of California
F
OREWORD
Pursuant to California Penal Code Section 6126 et seq., which assigns the Office of the Inspector
General (OIG) responsibility for oversight of the California Department of Corrections and
Rehabilitation (CDCR), the OIG conducts a comprehensive inspection program to evaluate the
delivery of medical care at each of CDCR’s 35 adult prisons. The OIG explicitly makes no
determination regarding the constitutionality of care in the prison setting. That determination is
left to the Receiver and the federal court. The assessment of care by the OIG is just one factor in
the court’s determination whether care in the prisons meets constitutional standards.
The OIG’s inspections are mandated by the Penal Code and not aimed at specifically resolving
the court’s questions on constitutional care. To the degree that they provide another factor for the
court to consider, the OIG is pleased to provide added value to the taxpayers of California.
In Cycle 5, for the first time, the OIG will be inspecting institutions delegated back to CDCR
from the Receivership. There is no difference in the standards used for assessment of a delegated
institution versus an institution not yet delegated. At the time of the Cycle 5 inspection of
Pleasant Valley State Prison, the Receiver had delegated this institution back to CDCR
(on July 31, 2017).
This fifth cycle of inspections will continue evaluating the areas addressed in Cycle 4, which
included clinical case review, compliance testing, and a population-based metric comparison of
selected Healthcare Effectiveness Data Information Set (HEDIS) measures. In agreement with
stakeholders, the OIG made changes to both the case review and compliance components. The
OIG found that in every inspection in Cycle 4, larger samples were taken than were needed to
assess the adequacy of medical care provided. As a result, the OIG reduced the number of case
reviews and sample sizes for compliance testing. Also, in Cycle 4, compliance testing included
two secondary (administrative) indicators (Internal Monitoring, Quality Improvement, and
Administrative Operations; and Job Performance, Training, Licensing, and Certifications). For
Cycle 5, these have been combined into one secondary indicator, Administrative Operations.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page i
Office of the Inspector General State of California
This page intentionally left blank.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page ii
Office of the Inspector General State of California
E S
XECUTIVE UMMARY
The OIG completed the Cycle 5 medical inspection of Pleasant
Valley State Prison (PVSP) in December 2018. The vast majority
OVERALL RATING:
of our inspection findings were based on PVSP’s health care
delivery between June 2017 and January 2018. Our policy
Inadequate
compliance inspectors performed an onsite inspection in November
2017. After reviewing the institution’s health care delivery, our
case review clinicians performed an onsite inspection in May 2018
to follow up on their findings.
Our clinician team, consisting of expert physicians and nurse consultants, reviewed cases (patient
medical records) and interpreted our policy compliance results to determine the quality of health
care the institution provided. Our compliance team, consisting of registered nurses, monitored
the institution’s compliance with its medical policies by answering a predetermined set of policy
compliance questions.
Our clinician team reviewed 46 cases that contained 725 patient-related events. Our compliance
team tested 88 policy questions by observing PVSP’s processes and examining 393 patient
records and 1,071 data points. We distilled the results from both the case review and compliance
testing into 13 health care indicators and have listed the individual indicators and ratings
applicable for this institution in the PVSP Executive Summary Table on the following page. Of
these 13 indicators, OIG inspectors rated one proficient, 6 adequate, and 6 inadequate. Our
experts made a considered and measured opinion that the overall quality of health care at PVSP
was inadequate.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page iii
Office of the Inspector General State of California
PVSP Executive Summary Table
Cycle 5 Cycle 4
Case Review Compliance
Inspection Indicators Overall Overall
Rating Rating
Rating Rating
1—Access to Care Adequate Proficient Adequate Proficient
2—Diagnostic Services Proficient Inadequate Adequate Proficient
3—Emergency Services Inadequate Not Applicable Inadequate Proficient
4—Health Information
Adequate Proficient Adequate Adequate
Management
5—Health Care Environment Not Applicable Inadequate Inadequate Proficient
6—Inter- and Intra-System
Inadequate Adequate Inadequate Adequate
Transfers
7—Pharmacy and Medication I
Inadequate Inadequate Inadequate n Proficient
Management
a
8—Prenatal and Post-Delivery
Not Applicable Not Applicable Not Applicable Not Applicable
Services
9—Preventive Services Not Applicable Proficient Proficient Adequate
10—Quality of Nursing
Inadequate Not Applicable Inadequate Adequate
Performance
11—Quality of Provider
Inadequate Not Applicable Inadequate Adequate
Performance
12—Reception Center Arrivals Not Applicable Not Applicable Not Applicable Not Applicable
13—Specialized Medical Housing Adequate Proficient Adequate Proficient
14—Specialty Services Adequate Adequate Adequate Proficient
15—Administrative Operations
Not Applicable Adequate Adequate Adequate*
(Secondary)
*In Cycle 4, there were two secondary (administrative) indicators. This score reflects the average of those
two scores.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page iv
Office of the Inspector General State of California
Expert Clinician Case Review Results
Our expert clinicians reviewed cases of patients with many medical needs and included a review
of 725 patient care events.1 The vast majority of our case review covered the period between
June 2017 and January 2018. As depicted on the executive summary table on page iv, we rated
10 of the 13 indicators applicable to PVSP. Of those ten applicable indicators, we rated one
proficient, four adequate, and five inadequate. When determining the overall adequacy of care,
we paid particular attention to the clinical nursing and provider quality indicators, as adequate
health care staff can sometimes overcome suboptimal compliance (i.e., performance with
processes and programs). However, the opposite is not true; inadequate health care staff cannot
provide adequate care, even though the established processes and programs may be adequate.
We identified inadequate medical care based on the risk of significant harm to the patient, not the
actual outcome.
Program Strengths — Clinical
• The providers reported good morale and felt well-supported by the medical leadership.
• PVSP continued to complete laboratory and radiology tests in accordance with the
providers’ orders.
• As long as staff correctly ordered appointments, the institution properly scheduled patients
to see providers or nurses timely.
Program Weaknesses — Clinical
• PVSP nurses and providers demonstrated poor emergency care. They repeatedly made errors
that placed patients at increased risk of harm, and in some cases those errors resulted in
harm.
• Sick call performance at the institution worsened since Cycle 4. Sick call nurses frequently
failed to make good assessments, intervene appropriately, or refer their patients to a
provider.
• PVSP had severe problems with medication management that may have been related to the
implementation of the new electronic health records system (EHRS). During this transition
period, the institution had no pharmacist in charge (PIC). We found poor medication
continuity in multiple areas, including transfers in, transfers out, hospital returns, and
chronic medications. Some of the mediation lapses occurred when nurses sometimes failed
to intervene for their patients who required medication renewal orders.
1 Each OIG clinician team consists of a board-certified physician and a registered nurse consultant with experience in
correctional and community medical settings.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page v
Office of the Inspector General State of California
• Specialty services processes at PVSP were fragmented and unorganized. The lack of
specialty services coordination resulted in the institution’s inability to reliably track
specialty appointments and properly retrieve specialty reports.
• PVSP had difficulty providing medical care seven days per week. When we asked about
some of the lapses in the care we found during the weekends, PVSP staff said they could not
accommodate any weekend provider care because of the lack of provider availability.
Furthermore, we found that PVSP did not schedule its providers to work every weekday; the
clinics typically lacked onsite provider coverage one or two customary workdays each week.
Compliance Testing Results
Of the 13 health care indicators applicable to PVSP, our compliance inspectors2 evaluated 10. Of
these, four were proficient, three were adequate, and three were inadequate. The vast majority of
our compliance testing was of medical care that occurred between February 2017 and
November 2017. There were 88 individual compliance questions within those ten indicators,
generating 1,071 data points that tested PVSP’s compliance with California Correctional Health
Care Services (CCHCS) policies and procedures.3 Appendix A — Compliance Test Results
provides details for the 88 questions.
Program Strengths — Compliance
The following are some of PVSP’s strengths based on its compliance scores for individual
questions in the health care indicators:
• The institution’s nursing staff and providers did an excellent job of completing initial health
assessments and evaluating patients admitted to specialized medical housing in a timely
manner.
• The institution offered influenza vaccinations and provided colorectal cancer screenings to
all sampled patients timely.
• PVSP nursing staff performed well with closely monitoring patients who were taking
tuberculosis (TB) medications.
• Nursing staff at PVSP reviewed health care services request forms and conducted
face-to-face encounters within required time frames.
2 The OIG’s compliance team consists of inspectors who are registered nurses with expertise in CDCR policies
regarding medical staff and processes.
3 The OIG used its own clinicians to provide clinical expert guidance for testing compliance in certain areas for which
CCHCS policies and procedures did not specifically address an issue.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page vi
Office of the Inspector General State of California
• The institution’s medical staff timely scanned non-dictated progress notes, initial health care
screening forms, community hospital discharge reports, and requests for health care services
into patients’ electronic medical records.
Program Weaknesses — Compliance
The following are some of the weaknesses identified by PVSP’s compliance scores for
individual questions in the health care indicators:
• Clinicians at PVSP did not follow proper hand hygiene practices before or after patient
encounters.
• Clinic examination rooms were missing essential core medical equipment and supplies, as
well as properly calibrated equipment necessary to perform a comprehensive exam.
• Providers performed poorly with communicating diagnostic test results to patients.
• PVSP’s pharmacy did not appropriately store refrigerated or non-refrigerated medications.
Staff stored personal items in medication preparation areas, and medications were stored
beyond manufacturers’ guidelines.
Recommendations
The OIG recommends the following:
• The chief executive officer (CEO) should correct the review process of the Emergency
Medical Response Review Committee (EMRRC); the EMRRC failed to identify problems
with the institution’s emergency response and care provided by providers and nurses in the
triage and treatment center (TTA). PVSP needs a properly functioning EMRRC to identify
and correct the institution’s various lapses in emergency care.
• The CEO should address the numerous problems related to medications at PVSP by first
improving the pharmacy’s staffing levels. The pharmacist in charge (PIC) and the chief
nursing executive (CNE) should then implement quality improvement measures to address
the numerous problems with medication management we found during this inspection.
• The CNE and the PIC should correct and then monitor the medication transfer process to
ensure medication continuity for patients transferring into and out of PVSP or returning
from an outside hospital. During our inspection, we found serious problems with medication
continuity in all transfer processes.
• The CNE should provide training to, and monitor, nurses in the receiving and release (R&R)
and the TTA, as these nurses are the primary staff responsible for coordinating and ensuring
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page vii
Office of the Inspector General State of California
the continuity of care for patients in these areas. During our inspection, nurses in R&R and
the TTA did not fulfill their responsibilities sufficiently.
• The CEO should revamp the specialty services processes to ensure PVSP staff coordinate
their efforts to deliver appropriate specialty care. During our inspection, we found a lack of
coordination, resulting in poor tracking of specialty appointments and sporadic performance
with retrieving specialty reports at PVSP. The CEO and the CNE should also develop and
implement a process that will ensure the institution’s staff refer patients who refuse specialty
services back to the primary provider for further evaluation.
• The chief medical executive (CME) should refine the current methods used to evaluate
provider performance since we found problems with provider performance in the emergency
setting and issues with superficial reviews of medical records.
Population-Based Metrics
In general, PVSP performed comparably to other health plans as measured by population-based
metrics. In comprehensive diabetes care, PVSP outperformed most state and national health care
plans in the five diabetic measures. However, the institution scored lower than four health care
plans for diabetic eye exams.
With regard to immunization measures, PVSP scored higher than two, but lower than three
health care plans for influenza immunizations for younger adults. No comparative data was
available regarding vaccinations for older adults because PVSP did not have any patients 65
years of age or older at the time of inspection. Colorectal cancer screening scores were mixed,
with the institution scoring higher than two health plans, matching the score of one health plan,
and scoring lower than two other health plans.
PVSP may improve its scores for immunizations by reducing patient refusals through educating
patients on the benefits of these preventive services.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page viii
Office of the Inspector General State of California
I
NTRODUCTION
Pursuant to California Penal Code Section 6126 et seq., which assigns the Office of the Inspector
General (OIG) responsibility for oversight of the California Department of Corrections and
Rehabilitation (CDCR), and at the request of the federal Receiver, the OIG developed a
comprehensive medical inspection program to evaluate the delivery of medical care at each of
CDCR’s 35 adult prisons. The OIG conducted a clinical case review and a compliance
inspection, ensuring a thorough, end-to-end assessment of medical care within CDCR.
Pleasant Valley State Prison (PVSP) was the 31st medical inspection of Cycle 5. During the
inspection process, the OIG assessed the delivery of medical care to patients using the primary
clinical health care indicators applicable to the institution. The Administrative Operations
indicator is secondary because it does not reflect the actual clinical care provided.
ABOUT THE INSTITUTION
Pleasant Valley State Prison (PVSP) opened in 1994, and is located in Coalinga, in Fresno
County. The institution houses general population, minimum- to maximum-custody patients.
PVSP operates six medical clinics where staff members handle non-urgent requests for medical
services. PVSP also conducts screenings in its receiving and release (R&R) clinical area; treats
patients needing urgent or emergency care in its triage and treatment area (TTA); and treats those
requiring inpatient health services in its correctional treatment center (CTC). The institution
primarily provides medical care for patients designated as low to medium medical risk; however,
it does have a very small population of patients classified as high medical risk. California
Correctional Health Care Services (CCHCS) has designated PVSP a “basic” health care
institution, an institution located in a rural area away from tertiary care centers and specialty care
providers whose services would likely be used frequently by higher-risk patients. PVSP’s
geographical location is in the western San Joaquin Valley, and the institution is one of two
California prisons designated as a restricted area for patients who are at high risk for contracting
coccidioidomycosis (“valley fever”).
The institution received national accreditation from the Commission on Accreditation for
Corrections in August 2016. This accreditation program is a professional peer review process
based on national standards set by the American Correctional Association.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 1
Office of the Inspector General State of California
Based on staffing data we obtained from the institution as identified in the following PVSP
Health Care Staffing Resources table as of November 2017 table, PVSP’s average vacancy rate
was approximately 3 percent.
PVSP Health Care Staffing Resources as of November 2017
Primary
Executive Nursing Nursing
Care Total
Leadership* Supervisors Staff**
Providers
Authorized Positions 5.0 7.0 10.5 90.6 113.1
Filled by Civil Service 5.0 6.3 10.0 88.5 109.8
Vacant 0.0 0.7 0.5 2.1 3.3
Percent Filled by Civil Service 100.0% 90.0% 95.2% 97.7% 97.1%
Filled by Telemed 0.0 0.3 0.0 0.0 0.3
Percent Filled by Telemed 0.0% 4.3% 0.0% 0.0% 0.3%
Filled by Registry 0.0 0.0 0.0 4.02 4.0
Percent Filled by Registry 0.0% 0.0% 0.0% 4.4% 3.6%
Total Filled Positions 5.0 6.6 10.0 92.5 114.1
Total percentage Filled 100.0% 94.3% 95.2% 102.2% 100.9%
Appointments in last 12 Months 1.0 1.0 8.0 11.0 21.0
Redirected Staff 0.0 0.0 0.0 1.0 1.0
Staff on Extended Leave^ 0.0 0.0 0.0 2.0 2.0
Adjusted Total: Filled Positions 5.0 6.6 10.0 89.5 111.1
Adjusted Total: percentage Filled 100.0% 94.3% 95.2% 98.8% 98.3%
* Executive Leadership includes Chief Physician & Surgeon.
** Nursing Staff includes Senior Psychiatric Technician/Psychiatric Technician.
^ In Authorized Positions.
Note: The OIG did not validate the PVSP Health Care Staffing Resources and Filled Positions data.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 2
Office of the Inspector General State of California
As of October 30, 2017, the Master Registry for PVSP showed that the institution had a total
population of 2,842. Within that total population, 0.1 percent was designated as high medical
risk, Priority 1 (High 1), and 0.2 percent was designated as high medical risk, Priority 2 (High 2).
Patients’ assigned risk levels are based on the complexity of their required medical care related
to their specific diagnoses, frequency of higher levels of care, age, and abnormal laboratory
results and procedures. High 1 has at least two high-risk conditions; High 2 has only one.
Patients at high medical risk are more susceptible to poor health outcomes than those at medium
or low medical risk. Patients at high medical risk also typically require more health care services
than do patients with lower assigned risk levels. The table below illustrates the breakdown of the
institution’s medical risk levels at the start of the OIG medical inspection.
PVSP Master Registry Data as of October 30, 2017
Medical Risk Level Number of Patients Percentage
High 1 2 0.1%
High 2 7 0.2%
Medium 1,114 39.2%
Low 1,719 60.5%
Total 2,842 100.%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 3
Office of the Inspector General State of California
O , S , M
BJECTIVES COPE AND ETHODOLOGY
In designing the medical inspection program, the OIG reviewed CCHCS policies and procedures,
relevant court orders, and guidance developed by the American Correctional Association. The
OIG also reviewed professional literature on correctional medical care; reviewed standardized
performance measures used by the health care industry; consulted with clinical experts; and met
with stakeholders from the court, the Receiver’s office, CDCR, the Office of the Attorney
General, and the Prison Law Office to discuss the nature and scope of the OIG’s inspection
program. With input from these stakeholders, the OIG developed a medical inspection program
that evaluates medical care delivery by combining clinical case reviews of patient files, objective
tests of compliance with policies and procedures, and an analysis of outcomes for certain
population-based metrics.
To maintain a metric-oriented inspection program that evaluates medical care delivery
consistently at each state prison, the OIG identified 15 indicators (14 primary (clinical) indicators
and one secondary (administrative) indicator) of health care to measure. The primary quality
indicators cover clinical categories directly relating to the health care provided to patients,
whereas the secondary quality indicator addresses the administrative functions that support a
health care delivery system. The PVSP Executive Summary Table on page iv of this report
identifies these 15 indicators.
The OIG rates each of the quality indicators applicable to the institution under inspection based
on case reviews conducted by OIG clinicians and compliance tests conducted by OIG registered
nurses. The case review results alone, the compliance test results alone, or a combination of both
these information sources may influence an indicator’s overall rating. For example, the OIG
derives the ratings for the primary quality indicators Quality of Nursing Performance and
Quality of Provider Performance entirely from the case review done by clinicians, while the
ratings for the primary quality indicators Health Care Environment and Preventive Services are
derived entirely from compliance testing done by registered nurse inspectors. As another
example, primary quality indicators such as Diagnostic Services and Specialty Services receive
ratings derived from both sources.
The OIG does not inspect for efficiency or cost-effectiveness of medical operations. Consistent
with the OIG’s agreement with the Receiver, this report only addresses the quality of CDCR’s
medical operations and its compliance with quality-related policies. Moreover, if the OIG learns
of a patient needing immediate care, the OIG notifies the chief executive officer of health care
services and requests a status report. In addition, if the OIG learns of significant departures from
community standards, it may report such departures to the institution’s chief executive officer or
to CCHCS. Because these matters involve confidential medical information protected by state
and federal privacy laws, the OIG does not include specific identifying details related to any such
cases in the public report.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 4
Office of the Inspector General State of California
In all areas, the OIG is alert for opportunities to make appropriate recommendations for
improvement. Such opportunities may be present regardless of the score awarded to any
particular quality indicator; therefore, recommendations for improvement are not necessarily
indicative of deficient medical care delivery.
CASE REVIEWS
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of its
stakeholders, which continues in the Cycle 5 medical inspections. The following exhibit provides
definitions that describe this process.
Exhibit 1. Case Review Definitions
Case = Sample = Patient
An appraisal of the medical care provided to one patient over a specific
period, which can comprise detailed or focused case reviews.
Detailed Case Review
A review that includes all aspects of one patient’s medical care assessed over
a six-month period. This review allows the OIG clinicians to examine many
areas of health care delivery, such as access to care, diagnostic services,
health information management, and specialty services.
Focused Case Review
A review that focuses on one specific aspect of medical care. This review
tends to concentrate on a singular facet of patient care, such as the sick call
process or the institution’s emergency medical response.
Case Review Event
A direct or indirect interaction between the patient and the health care system.
Examples of direct interactions include provider encounters and nurse
encounters. An example of an indirect interaction includes a provider
reviewing a diagnostic test and placing additional orders.
Case Review Deficiency
A medical error in procedure or in clinical judgment. Both procedural and
clinical judgment errors can result in policy non-compliance, elevated risk of
patient harm, or both.
Adverse Deficiency
A medical error that increases the risk of, or results in, serious patient harm.
Most health care organizations refer to these errors as adverse events.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 5
Office of the Inspector General State of California
The OIG’s clinicians perform a retrospective case review of selected patient files to evaluate the
care given by an institution’s primary care providers and nurses. Retrospective case review is a
well-established review process used by health care organizations that perform peer reviews and
patient death reviews. Currently, CCHCS uses retrospective case review as part of its death
review process and in its pattern-of-practice reviews. CCHCS also uses a more limited form of
retrospective case review when performing appraisals of individual primary care providers.
Patient Selection for Retrospective Case Reviews
Because retrospective case review is time consuming and requires qualified health care
professionals to perform it, the OIG must carefully select a sample of patient records for clinician
review. Accordingly, the group of patients the OIG targeted for case review carried the highest
clinical risk and utilized the majority of medical services. The majority of patients selected for
retrospective case review were high-utilizing patients with chronic care illnesses who were
classified as high or medium risk. The reason the OIG targeted these patients for review is
twofold:
1. The goal of retrospective case review is to evaluate all aspects of the health care system.
Statewide, high-risk and high-utilization patients consume medical services at a
disproportionate rate; 11 percent of the total patient population is high-risk and accounts
for more than half of the institution’s pharmaceutical, specialty, community hospital, and
emergency costs.
2. Selecting this target group for case review provides a significantly greater opportunity to
evaluate all the various aspects of the health care delivery system at an institution.
Underlying the choice of high-risk patients for detailed case review, the OIG clinical experts
made the following three assumptions:
1. If the institution is able to provide adequate clinical care to the most challenging patients
with multiple complex and interdependent medical problems, it is more likely to provide
adequate care to patients with less complicated health care issues. Because clinical
expertise is required to determine whether the institution has provided adequate clinical
care, the OIG utilizes experienced correctional physicians and registered nurses to
perform this analysis.
2. The health of less complex patients is more likely to be affected by processes such as
timely appointment scheduling, medication management, routine health screening, and
immunizations. To review these processes, the OIG simultaneously performs a broad
compliance review.
3. Patient cases generated during death reviews, sentinel events (unexpected occurrences
involving death or serious injury, or risk thereof), and hospitalizations are more likely to
comprise high-risk patients.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 6
Office of the Inspector General State of California
Benefits and Limitations of Targeted Subpopulation Review
Because the patients selected utilize the broadest range of services offered by the health care
system, the OIG’s retrospective case review provides adequate data for a qualitative assessment
of the most vital system processes (referred to as “primary quality indicators”). Retrospective
case review provides an accurate qualitative assessment of the relevant primary quality indicators
as applied to the targeted subpopulation of high-risk and high-utilization patients. While this
targeted subpopulation does not represent the prison population as a whole, the institution’s
ability to respond with adequate medical care to this subpopulation is a crucial and vital indicator
of how the institution provides health care to its whole patient population. Simply put, if the
institution’s medical system does not respond adequately for those patients needing the most
care, then it is not fulfilling its obligations, even if it takes good care of patients with less
complex medical needs.
Since the targeted subpopulation does not represent the institution’s general prison population,
the OIG cautions against inappropriate extrapolation of medical conditions or outcomes from the
retrospective case reviews to the general population. For example, if the high-risk diabetic
patients reviewed have poorly controlled diabetes, one cannot conclude that all the diabetics’
conditions are poorly controlled. Similarly, if the high-risk diabetic patients under review have
poor outcomes, one cannot conclude that the entire diabetic population is having similarly poor
outcomes. The OIG does not extrapolate conditions or outcomes, but instead extrapolates the
institution’s response for those patients needing the most care because the response yields
valuable system information.
In the above example, if the institution responds by providing appropriate diabetic monitoring,
medication therapy, and specialty referrals for the high-risk patients reviewed, then it is
reasonable to infer that the institution is also responding appropriately to all the diabetics in the
prison. However, if these same high-risk patients needing monitoring, medications, and referrals
are not getting those needed services, it is likely that the institution is not providing appropriate
diabetic services.
Case Review Sampling Methodology
Using a pre-defined case review sampling algorithm, OIG analysts apply various filters to each
institution’s patient population. The various filters include medical risk status, number of
prescriptions, number of specialty appointments, number of clinic appointments, and other
health-related data. The OIG uses these filters to narrow down the population to those patients
with the highest utilization of medical resources (see Chart 1, next page). To prevent selection
bias, the OIG ensures that the same clinicians who perform the case reviews do not participate in
the sample selection process.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 7
Office of the Inspector General State of California
Chart 1. Case Review Sample Selection
The OIG’s case sample sizes matched those of other qualitative research. The empirical findings,
supported by expert statistical consultants, showed adequate conclusions after 10 to 15 cases had
undergone comprehensive, or detailed, clinician review. In qualitative statistics, this
phenomenon is known as “saturation.” The OIG found the Cycle 4 medical inspection sample
size of 30 for detailed physician reviews far exceeded the saturation point necessary for an
adequate qualitative review. At the end of Cycle 4 inspections, the OIG re-analyzed the case
review results using half the number of cases; there were no significant differences in the ratings.
To improve inspection efficiency while preserving the quality of the inspection, the OIG reduced
the number of the samples for Cycle 5 medical inspections to the current levels. For most basic
institutions, the OIG samples 20 cases for detailed physician review. For intermediate institutions
and several basic institutions with larger high-risk populations, the OIG samples 25 cases. For
California Health Care Facility, the OIG samples 30 cases for detailed physician review.
Breadth of Case Reviews
As indicated in Appendix B, Table B-1: PVSP Sample Sets, the OIG clinicians evaluated medical
records for 46 unique cases. Appendix B, Table B-4: PVSP Case Review Sample Summary
clarifies that both nurses and physicians reviewed 16 of those cases, for 62 case reviews in total.
Physicians performed detailed reviews of 22 cases, and nurses performed detailed reviews of
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 8
Office of the Inspector General State of California
15 cases, totaling 37 detailed case reviews. Physicians and nurses also performed a focused
review of an additional 25 cases. These reviews generated 725 case review events (Appendix B,
Table B-3: PVSP Event – Program).
While the sample method specifically pulled only 3 chronic care cases, i.e., 3 diabetes cases
(Appendix B, Table B-1: PVSP Sample Sets), the 46 unique cases sampled included 117 chronic
care diagnoses, including one additional case with diabetes (for a total of 4) (Appendix B, Table
B-2: PVSP Chronic Care Diagnoses). The OIG’s sample selection tool allowed evaluation of
many chronic care programs because the complex and high-risk patients selected from the
different categories often had multiple medical problems. While the OIG did not evaluate every
chronic disease or health care staff member, the OIG did assess for adequacy the overall
operation of the institution’s system and staff.
Case Review Testing Methodology
A physician, a nurse consultant, or both clinician inspectors review each case. The OIG clinician
inspector can perform one of two different types of case review: detailed or focused (see
Exhibit 1, page 5, and Chart 1, previous page). As the OIG clinician inspector reviews the
medical record for each sample, the inspector records pertinent interactions between the patient
and the health care system. These interactions are also known as case review events. When an
OIG clinician inspector identifies a medical error, the inspector also records these errors as case
review deficiencies. If a deficiency is of such magnitude that it caused, or had the potential to
cause, serious patient harm, then the OIG clinician records it as an adverse deficiency
(see Chart 2, next page).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 9
Office of the Inspector General State of California
Chart 2. Case Review Testing and Deficiencies
When the OIG clinician inspectors have reviewed all cases, they analyze the deficiencies. OIG
inspectors search for similar types of deficiencies to determine if a repeating pattern of errors
existed. When the same type of error occurs multiple times, the OIG inspectors identify those
errors as findings. When the error is frequent, the likelihood is high that the error is regularly
recurring at the institution. The OIG categorizes and summarizes these deficiencies in one or
more health care quality indicators in this report to help the institution focus on areas for
improvement.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 10
Office of the Inspector General State of California
The OIG physicians also rate each of the detailed physician cases for adequacy based on whether
the institution met the patient’s medical needs and if it placed the patient at significant risk of
harm. The cumulative analysis of these cases gives the OIG clinicians additional perspective to
help determine whether the institution is providing adequate medical services or not.4
Based on the collective results of clinicians’ case reviews, the OIG clinicians rated each quality
indicator proficient (excellent), adequate (passing), or inadequate (failing). A separate
confidential PVSP Supplemental Medical Inspection Results: Individual Case Review Summaries
report details the case reviews the OIG clinicians conducted and is available to specific
stakeholders. For further details regarding the sampling methodologies and counts, see
Appendix B — Clinical Data, Table B-1; Table B-2; Table B-3; and Table B-4.
4 Regarding individual provider performance, the OIG did not design the medical inspection to be a focused search for
poorly performing providers; rather, the inspection assesses each institution’s systemic health care processes.
Nonetheless, while the OIG does not purposefully sample cases to review each provider at the institution, the cases
usually involve most of the institutions’ providers. Providers should only escape OIG case review if institutional
managers assigned poorly performing providers the care of low-utilizing and low-risk patients, or if the institution had a
relatively high number of providers.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 11
Office of the Inspector General State of California
COMPLIANCE TESTING
Sampling Methods for Conducting Compliance Testing
Our registered nurse inspectors obtained answers to 88 objective medical inspection test (MIT)
questions designed to assess the institution’s compliance with critical policies and procedures
applicable to the delivery of medical care. To conduct most tests, inspectors randomly selected
samples of patients for whom the testing objectives were applicable and reviewed their electronic
medical records. In some cases, inspectors used the same samples to conduct more than one test.
In total, inspectors reviewed health records for 393 individual patients and analyzed specific
transactions within their records for evidence that critical events occurred. Inspectors also
reviewed management reports and meeting minutes to assess certain administrative operations.
In addition, during the week of November 13, 2017, registered nurse field inspectors conducted a
detailed onsite inspection of PVSP’s medical facilities and clinics; interviewed key institutional
employees; and reviewed employee records, logs, medical appeals, death reports, and other
documents. This generated 1,071 scored data points to assess care.
In addition to the scored questions, the OIG obtained information from the institution that it did
not score. This included, for example, information about PVSP’s plant infrastructure, protocols
for tracking medical appeals and local operating procedures, and staffing resources.
For details of the compliance results, see Appendix A — Compliance Test Results. For details of
the OIG’s compliance sampling methodology, see Appendix C — Compliance Sampling
Methodology.
Scoring of Compliance Testing Results
After compiling the answers to the 88 questions for the ten indicators for which compliance
testing was applicable, the OIG compliance team derived a score for each quality indicator by
calculating the percentage score of all Yes answers for each of the questions applicable to a
particular indicator, then averaging those scores. Based on those results, the OIG assigned a
rating to each quality indicator of proficient (greater than 85 percent), adequate (between
75 percent and 85 percent), or inadequate (less than 75 percent).
OVERALL QUALITY INDICATOR RATING FOR CASE REVIEWS AND COMPLIANCE
TESTING
The OIG derived the final rating for each quality indicator by combining the ratings from the
case reviews and from the compliance testing, as applicable. When combining these ratings, the
case review evaluations and the compliance testing results usually agreed, but there were
instances for this inspection when the rating differed for a particular quality indicator. In those
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 12
Office of the Inspector General State of California
instances, the inspection team assessed the quality indicator based on the collective ratings from
both components. Specifically, the OIG clinicians and registered nurse inspectors discussed the
nature of individual exceptions found within that indicator category and considered the overall
effect on the ability of patients to receive adequate medical care.
To derive an overall assessment rating of the institution’s medical inspection, the OIG evaluated
the various rating categories assigned to each of the quality indicators applicable to the
institution, giving more weight to the rating results of the primary quality indicators, which
directly relate to the health care provided to patients. Based on that analysis, OIG experts made a
considered and measured overall opinion about the quality of health care observed.
POPULATION-BASED METRICS
The OIG identified a subset of Healthcare Effectiveness Data Information Set (HEDIS) measures
applicable to the CDCR patient population. To identify outcomes for PVSP, the OIG reviewed
some of the compliance testing results, randomly sampled additional patients’ records, and
obtained PVSP data from the CCHCS Master Registry. The OIG compared those results to
HEDIS metrics reported by other statewide and national health care organizations.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 13
Office of the Inspector General State of California
M I R
EDICAL NSPECTION ESULTS
The OIG’s case review and clinician teams use quality indicators to assess the clinical aspects of
health care. The PVSP Executive Summary Table on page iv of this report identifies the
13 indicators applicable to this institution. The following chart depicts their union and
intersection:
Chart 3. Inspection Indicator Review Distribution
The Administrative Operations indicator is a secondary indicator; therefore, the OIG did not rely
upon this indicator when determining the institution’s overall score. Based on the analysis and
results in all the primary indicators, the OIG experts made a considered and measured opinion
that the quality of health care at PVSP was inadequate.
Summary of Case Review Results: The clinical case review component assessed 10 of the
13 primary (clinical) indicators applicable to PVSP. Of these ten indicators, OIG clinicians rated
one proficient, four adequate, and five inadequate.
The OIG physicians rated the overall adequacy of care for each of the 22 detailed case reviews
they conducted. Of these 22 cases, one was proficient, 14 were adequate, and 7 were inadequate.
In the 725 events reviewed, there were 145 deficiencies, 52 of which were considered to be of
such magnitude that, if left unaddressed, they would likely contribute to patient harm.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 14
Office of the Inspector General State of California
Adverse Deficiencies Identified During Case Review: Adverse deficiencies are medical errors
that markedly increased the risk of, or resulted in, serious patient harm. Medical care is a
complex and dynamic process with many moving parts, subject to human error even within the
best health care organizations. All major health care organizations typically identify and track
adverse deficiencies for the purpose of quality improvement. Adverse deficiencies are not
typically representative of medical care delivered by the organization. The OIG normally
identifies adverse deficiencies for the dual purposes of quality improvement and the illustration
of problematic patterns of practice found during the inspection. Because of the anecdotal nature
of these deficiencies, the OIG cautions against drawing inappropriate conclusions regarding the
institution based solely on adverse deficiencies. The OIG identified six adverse deficiencies in
the case reviews at PVSP:
• In case 1, the patient with seizures transferred into PVSP. Even though the R&R nurse saw
the patient during normal business hours, the nurse failed to timely notify a provider
regarding the patient’s seizure medications. The nurse also failed to ensure continuity of the
patient’s other essential medications. Partially due to the nurse’s errors, the patient’s
medications lapsed, and he developed seizures two days after he arrived, requiring health
care staff to send the patient to an outside emergency department (ED). We also discuss this
case in the Inter- and Intra-System Transfers and the Pharmacy and Medication
Management indicators.
• In case 2, staff found the patient unresponsive in his cell with shallow, slow breathing and
critically low oxygen levels. The first medical responder (FMR) and subsequent health care
staff failed to provide sufficient respiratory support. The nurse inappropriately administered
low-flow oxygen instead of high-flow oxygen. When the patient arrived at the TTA, a nurse
began high-flow oxygen, but the provider inexplicably changed the oxygen back to
low-flow. None of the medical staff provided ventilation (assistance with breathing), even
though the patient’s oxygen levels remained critically low and the patient complained of
difficulty with breathing. Fortunately, the patient recovered with no obvious signs of
permanent injury after an outside hospitalization. We also discuss this case in the
Emergency Services and the Quality of Provider Performance indicators.
• In case 3, the patient had risk factors for cardiac disease and developed chest pain. The
patient was transported to the TTA, where staff made serious errors that placed the patient at
risk of complications from delayed evaluation of chest pain. The TTA nurse did not follow
chest pain protocol and did not administer nitroglycerin (medication to dilate arteries) or
aspirin until 40 minutes after receiving the order from the on-call provider. The nurse did
not insert an IV (intravenous access) until 109 minutes after the patient arrived. The provider
failed to evaluate the patient promptly and delayed sending the patient, who may have been
having a heart attack, to the ED for 90 minutes. Even after the provider ordered the nurse to
transfer the patient to the ED, the nurse waited an additional 23 minutes before calling 9-1-1.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 15
Office of the Inspector General State of California
We also discuss this case in the Emergency Services and the Quality of Provider
Performance indicators.
• In case 4, the patient overdosed on an unknown substance. The initial emergency response
was appropriate with medical staff administering naloxone (a medication used to reverse
opioid overdose temporarily) with good results. However, the on-call provider did not
evaluate the patient properly. The patient needed more monitoring because he could have
been in danger when the naloxone wore off. The patient also needed diagnostic testing to
determine which drug he had taken and whether he had any metabolic imbalances from the
overdose. Unfortunately, the provider failed to examine the patient, did not arrange the
needed monitoring or testing, and inappropriately released the patient back to regular
housing. The patient overdosed again two days later. We also discuss this case in the
Emergency Services and the Quality of Provider Performance indicators.
• In case 6, the patient was unresponsive, not breathing, and without a pulse. Staff began CPR,
but failed to call 9-1-1 until they transported the patient to the TTA 20 minutes later. This
was a severe delay in calling 9-1-1. PVSP staff delayed advanced cardiovascular life support
(ACLS) measures until offsite paramedics arrived. Unfortunately, the ACLS efforts were
unsuccessful, and the patient died in the TTA. We also discuss this case in the Emergency
Services indicator.
• In case 13, the patient was shivering, had a bad headache, was vomiting, and had elevated
blood pressure and heart rate. The patient had warning signs and symptoms of a serious
neurological condition, but the nurse did not recheck the patient’s abnormal vital signs or
contact a provider. Instead, the nurse ordered a routine provider follow-up appointment and
sent the patient back to his housing unit with the unresolved symptoms. The following day,
the patient submitted another sick call request for a recurring headache. The nurse found the
patient with persistently elevated blood pressure and contacted a provider. The provider
ordered the patient have another blood pressure check later that afternoon, but the nurses
failed to do the check. On the third day, the patient developed a sudden loss of vision and
had persistent vomiting, uncontrolled blood pressure, and an explosive headache. The
provider intervened, examined the patient, and sent the patient to an offsite hospital.
Hospital physicians diagnosed the patient with a bleeding brain aneurysm and performed
extensive brain surgery to save his life. We also discuss this case in the Quality of Nursing
Performance indicator.
Summary of Compliance Results: The compliance component assessed 10 of the 13 indicators
applicable to PVSP. Of these ten indicators, OIG inspectors rated four proficient, three adequate,
and three inadequate. Each section of this report summarizes the results of those assessments,
whereas Appendix A provides the details of the test questions used to assess compliance for each
indicator.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 16
Office of the Inspector General State of California
ACCESS TO CARE
This indicator evaluates the institution’s ability to provide patients
Case Review Rating:
with timely clinical appointments. Compliance and case review Adequate
teams review areas specific to patients’ access to care, such as initial Compliance Score:
assessments of newly arriving patients, acute and chronic care Proficient
(87.4%)
follow-ups, face-to-face nurse appointments when patients request to
be seen, provider referrals from nursing lines, and follow-ups after Overall Rating:
hospitalization or specialty care. Compliance testing for this Adequate
indicator also evaluates whether patients have Health Care Services
Request forms (CDCR Form 7362) available in their housing units.
For this indicator, the case review and compliance review processes yielded different results,
with the case reviewers assigning an adequate rating and the compliance testing resulting in a
proficient score. Although PVSP proficiently scheduled appointments when staff ordered
appointments correctly, our case review clinicians found that the institution’s staff did not
reliably order appointments correctly and that those errors resulted in delays in care. Despite
those delays, we determined the overall rating for this indicator was adequate because those
delays were seldom clinically significant.
Case Review Results
The OIG clinicians reviewed 150 provider, nurse, specialty, and hospital events that required a
follow-up appointment. There were 11 deficiencies relating to Access to Care¸ 7 of which were
significant. The case review rating for this indicator was adequate.
Provider Follow-up Appointments
We reviewed 68 provider encounters requiring a follow-up appointment with another provider.
As long as medical staff entered orders for the requested appointments, the institution reliably
scheduled them. However, medical staff errors resulted in some notable lapses:
• In case 1, the sick call nurse recorded the intention to refer the patient to the provider. When
making a provider referral, CCHCS policy requires the nurse to choose a follow-up interval
within 14 days and to complete and document that intervention. The nurse recorded the
intent to refer the patient to the provider in 14 days, but failed to enter the order. The patient
should have been seen in two weeks, but instead the patient had to wait a month to see the
provider because of the nurse’s error.
• In case 18, the patient refused an appointment for management of a serious left arm wound.
Medical staff did not properly inform the patient of the recommended intervention (wound
monitoring), or the consequences of his refusal (worsening infection and the cessation of
wound care) (Figure 1, p. 18). The provider did not review the patient’s medical condition
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 17
Office of the Inspector General State of California
and failed to request any further follow-up. Because of these errors, the institution
completely stopped caring for the patient’s wound with no further monitoring.
Figure 1: Refusal documentation for Case 18, which indicates staff failed inform the patient of the
recommended intervention (wound monitoring) and the consequences of refusing the appointment
(worsening wound infection and cessation of wound care).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 18
Office of the Inspector General State of California
RN Sick Call Access
In general, the 139 registered nurse (RN) sick call appointments we reviewed occurred timely.
There was one minor deficiency:
• In case 39, the patient described pain in his body on a sick call request. CCHCS policy
requires nurses to examine patients who describe symptoms on a sick call request within one
business day to ensure prompt intervention if the patient had urgent medical needs. The
nurse saw the patient one day late.
Provider Follow-up After Specialty Services
We reviewed 11 specialty service encounters requiring a provider follow-up visit and found all
occurred timely.
Intra-System Transfers / Reception Center
We reviewed the cases of eight patients who transferred into PVSP and needed a provider
encounter. Most patients we reviewed were seen timely. We identified only one deficiency:
• In case 25, the patient transferred into PVSP. The nurse ordered a provider intake referral
within 30 days, but the appointment was never scheduled.
Follow-up After Hospitalization
We reviewed four cases in which patients required a provider follow-up visit following a hospital
discharge. We found one minor deficiency:
• In case 19, the patient returned from the hospital after an evaluation for chest pain. CCHCS
policy requires these patients to be seen within five calendar days by their primary care
providers. The nurse erroneously entered a six-day appointment order and the patient was
seen one day late.
Follow-up After Urgent or Emergent Care
We reviewed nine TTA encounters that required a provider follow-up appointment and identified
deficiencies in the following cases:
• In case 14, the TTA nurse evaluated the patient for dizziness when standing. The nurse
contacted the on-call provider, who ordered a one-day follow-up appointment for the
patient. The nurse erroneously entered a three-day appointment request.
• In case 18, the patient was seen in the TTA for abdominal pain. The provider requested a
one-day follow-up appointment to exclude a serious disorder, such as appendicitis.
However, the provider erroneously entered a three-day appointment request.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 19
Office of the Inspector General State of California
Specialized Medical Housing
We reviewed eight specialized medical housing admissions that required provider follow-up
visits. All admissions occurred timely without deficiencies.
Specialty Access and Follow-up
We reviewed 11 specialty service visits that required a specialty consultant appointment and
provider follow-up visit. We found two deficiencies, both of which were significant:
• In case 21, the ophthalmologist advised a two-month follow-up appointment for the patient.
The appointment did not occur.
• In case 39, the patient refused a cardiology consultation and stress test and wished to be
rescheduled. The specialty nurse failed to refer the patient back to his provider to reorder the
services. Because of this error, the provider did not re-evaluate the patient for his cardiac
condition, and no further cardiac services were scheduled.
We also discuss performance in this area in the Specialty Services indicator.
Diagnostic Results Follow-up
We reviewed 40 diagnostic encounters that required the provider follow up with the patient after
an abnormal result. All occurred timely without a deficiency.
Clinician Onsite Inspection
Our inspection period included the institution’s transition to the EHRS. Following
implementation of the EHRS, nurses and providers were required to enter orders for follow-up
appointments. Unfamiliarity with the new processes in the EHRS may have contributed to some
of the errors we found during our inspection.
When asked about the one-day follow-up appointments ordered as three-day follow-up
appointments, PVSP staff explained that the one-day follow-up appointments could not have
been ordered because the appointments would have fallen on a weekend. Those types of
appointments needed to wait until the following Monday because PVSP could not provide
medical care over the weekend. The OIG does not agree with PVSP’s practice of delaying
medical care on the weekends for patients with acute medical problems. The institution
schedules onsite nurses 24 hours per day, 7 days per week. At least one PVSP provider is on-call
at all times to return to the institution to see patients when needed.
We also found the management of patients after they refused services to be potentially
problematic. When staff did not provide sufficient information for patients to make informed
decisions, the providers did not always make appropriate interventions to minimize their
patients’ risk of harm. Within CDCR institutions, medical staff usually intervene in these
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 20
Office of the Inspector General State of California
situations by ordering follow-up appointments. PVSP staff did not intervene in cases 18 and 39,
as we described previously.
Case Review Conclusion
In general, PVSP performed well with scheduling as long as staff ordered appointments in the
EHRS correctly. However, we found that staff did not consistently order these appointments
properly due to several reasons. These reasons included unfamiliarity with the EHRS, and the
intent to avoid scheduling care that fell on weekends. Nonetheless, most patients received care
promptly, and we rated this indicator adequate.
Compliance Testing Results
The institution performed in the proficient range, with a score of 87.4 percent in the Access to
Care indicator. The following tests earned scores in the proficient range:
• Nurses reviewed 29 of 30 sampled health care services request forms (CDCR Form 7362)
on the same day they were received (96.7 percent). Nursing staff failed to document the date
and time one patient’s request form was received and reviewed (MIT 1.003).
• For 27 of 29 sampled patients who submitted health care services request forms
(93.1 percent), nurses completed a face-to-face encounter with the patient within one
business day of reviewing the service request form. For two patients, nurses did not
document a complete progress note (MIT 1.004).
• PVSP provided follow-up appointments timely for all eight applicable patients whom nurses
referred to a provider and for whom the provider subsequently ordered a follow-up
appointment (MIT 1.006).
• PVSP offered 21 of 22 applicable patients a follow-up appointment with a provider within
five days of discharge from a community hospital (95.5 percent). The institution provided
one patient’s follow-up appointment one day late (MIT 1.007).
• Patients had access to health care services request forms at all six housing units inspected
(MIT 1.101).
Two tests received scores in the adequate range:
• We reviewed recent appointments for 25 sampled patients with chronic care conditions.
The institution provided follow-up appointments to 19 of the 25 patients (76.0 percent).
The institution provided follow-up appointments for five patients from 2 to 91 days late.
The institution did not provide a follow-up appointment for one other patient (MIT 1.001).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 21
Office of the Inspector General State of California
• Among 12 health care services request forms sampled, from which nursing staff referred the
patient for a provider appointment, the institution provided ten patients a timely appointment
(83.3 percent). The institution provided one patient’s appointment 28 days late. One other
patient’s appointment was not documented properly (MIT 1.005).
The OIG inspectors found room for improvement in the following two tests:
• Among 25 sampled patients who transferred into PVSP from other institutions and who
were referred to a provider based on the nurse’s initial health care screening, 17 patients
(68.0 percent) received timely provider appointments. The institution provided four patients
their provider appointments from one to 13 days late. The institution provided three other
patients’ provider appointments from 24 to 59 days late. One other patient did not receive a
provider appointment, but was seen by a nurse instead (MIT 1.002).
• The institution provided timely follow-up appointments with a provider to 17 of the
23 patients sampled who had received a high-priority or routine specialty service
(73.9 percent). The institution provided five patients’ follow-up appointments from one to
11 days late. One other patient did not receive a follow-up appointment with a provider at all
(MIT 1.008).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 22
Office of the Inspector General State of California
DIAGNOSTIC SERVICES
This indicator addresses several types of diagnostic services.
Case Review Rating:
Specifically, it addresses whether radiology and laboratory services Proficient
were timely provided to patients, whether primary care providers Compliance Score:
timely reviewed results, and whether providers communicated results Inadequate
(56.9%)
to the patient within required time frames. In addition, for pathology
services, the OIG determines whether the institution received a final Overall Rating:
pathology report and whether the provider timely reviewed and Adequate
communicated the pathology results to the patient. The case reviews
also factor in the appropriateness, accuracy, and quality of the diagnostic test(s) ordered and the
clinical response to the results.
For this indicator, the case review and compliance review processes yielded different results,
with the case reviewers assigning a proficient rating and the compliance testing resulting in an
inadequate score. Compliance testing showed providers regularly failed to review and sign
radiology reports, and had difficulty communicating test results to patients timely. However, our
case reviewers found that providers correctly acted on the test results and that their failure to
communicate the results to patients did not place patients at significant risk of harm. We
determined the overall rating for this indicator was adequate.
Case Review Results
We reviewed 97 diagnostic events and found four deficiencies related to health information
management, one of which was significant. Overall, we found PVSP improved its performance
in the Diagnostic Services indicator compared to Cycle 4; PVSP performed all tests as ordered
and had fewer deficiencies. The case review rating for this indicator was proficient.
Test Completion
All laboratory and radiology tests were performed in accordance with providers’ orders.
Health Information Management
In all four deficiencies we identified, the provider did not sign the diagnostic reports. For three of
the four deficiencies, the provider was aware of the results. The only significant error we found,
in which the provider did not review the report and was unaware of the results, was in the
following case:
• In case 17, the patient’s abnormal chest X-ray was not reviewed or signed by the provider.
Fortunately, the care of the patient was not affected by this error.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 23
Office of the Inspector General State of California
Clinician Onsite Inspection
According to PVSP leadership, implementing the EHRS contributed to the improvement of
diagnostic services at the institution. Since our inspection covered the period during which PVSP
transitioned to the EHRS, the institution’s leadership also attributed some of the remaining
deficiencies to incomplete staff training in the new system. Health care staff were optimistic
future deficiencies would improve since EHRS training opportunities in these areas had been
addressed.
Case Review Conclusion
PVSP performed well with regard to Diagnostic Services, and the indicator rating was thus
proficient.
Compliance Testing Results
The institution received an inadequate compliance score of 56.9 percent in the Diagnostic
Services indicator, which encompasses radiology, laboratory, and pathology services. For clarity,
we discuss each type of diagnostic service separately below:
Radiology Services
• The institution timely provided radiology services to all ten sampled patients (MIT 2.001).
PVSP providers then timely reviewed and signed the corresponding radiology test reports
for two of the ten patients (20.0 percent). Providers reviewed two patients’ reports 2 and
15 days late. For the other six patients, providers did not review the patients’ reports at all
(MIT 2.002). Providers also timely communicated radiology report results to five of the ten
patients (50.0 percent). Providers communicated report results to three patients from two to
six days late. The provider communicated the results 161 days late to one other patient. For
one final patient, the provider did not communicate the results at all (MIT 2.003).
Laboratory Services
• The institution timely provided laboratory services to nine of ten sampled patients
(90.0 percent). The institution did not provide the laboratory service on the scheduled date
as specified by the provider to one patient (MIT 2.004). PVSP providers then timely
reviewed eight of the ten resulting laboratory services reports (80.0 percent). Providers
reviewed two reports one and 24 days late (MIT 2.005). For the timely communication of
results to patients, PVSP scored zero. Providers communicated the results to two patients
9 and 41 days late, and did not communicate the results at all to one patient. Providers did
not specify the type of tests in their written communication to seven other patients
(MIT 2.006).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 24
Office of the Inspector General State of California
Pathology Services
• The institution timely retrieved the final pathology report for six of ten sampled patients
(60.0 percent). The institution retrieved two patients’ final reports one and 41 days late. The
institution did not retrieve final pathology reports at all for two other patients (MIT 2.007).
PVSP providers timely reviewed and signed the pathology results for seven of eight sampled
patients (87.5 percent). For one patient, the provider signed the report five days late
(MIT 2.008). In addition, providers timely communicated the final pathology results to only
two of the eight patients (25.0 percent). Providers communicated the final results to two
patients 5 and 70 days late. The provider did not specify the type of tests in his written
communication to one patient. Providers did not communicate the final results at all to three
patients (MIT 2.009).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 25
Office of the Inspector General State of California
EMERGENCY SERVICES
An emergency medical response system is essential to providing
Case Review Rating:
effective and timely emergency medical response, assessment,
Inadequate
treatment, and transportation 24 hours per day. Provision of
Compliance Score:
urgent/emergent care is based on a patient’s emergency situation,
Not Applicable
clinical condition, and need for a higher level of care. The OIG
Overall Rating:
reviews emergency response services including first aid, basic life
Inadequate
support (BLS), and advanced cardiac life support (ACLS) consistent
with the American Heart Association guidelines for cardiopulmonary
resuscitation (CPR) and emergency cardiovascular care, and the provision of services by
knowledgeable staff appropriate to each individual’s training, certification, and authorized scope
of practice.
The OIG evaluates this quality indicator entirely through clinicians’ reviews of case files and
conducts no separate compliance testing element.
Case Review Results
We reviewed 18 cases in which patients required urgent or emergent care. These cases yielded
25 urgent/emergent events and 24 deficiencies in various aspects of emergency care. Twelve
deficiencies were significant and occurred in cases 2, 3, 4, 5, 6, 8, 14, 15, and 18. Due to the
strong pattern of problematic emergency care, we rated this indicator inadequate.
Emergency Response
The institution’s emergency response staff had great difficulty providing appropriate basic life
support and often failed to activate 9-1-1 when indicated as noted in the following cases:
• In case 2, the unresponsive patient had shallow and slow breathing, and critically low
oxygen levels. The first medical responder and subsequent health care staff failed to provide
sufficient respiratory support. The nurse inappropriately administered low-flow oxygen
instead of high-flow oxygen. When the patient arrived at the TTA, a nurse began high-flow
oxygen, but the provider inexplicably changed the oxygen back to low-flow. No medical
staff provided ventilation (assistance with breathing) even though the patient’s oxygen levels
remained critically low and the patient complained of difficulty breathing. Fortunately, the
patient recovered with no obvious signs of permanent injury after an outside hospitalization.
• In case 3, the patient with risk factors for cardiac disease developed chest pain. The patient
arrived at the TTA, where staff made serious errors in his care. The nurse did not follow
chest pain protocol, failing to administer nitroglycerin (medication to dilate arteries) or
aspirin until 40 minutes after receiving the order from the on-call provider. The nurse did
not insert an IV (intravenous access) until 109 minutes after the patient arrived. The provider
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 26
Office of the Inspector General State of California
did not evaluate the patient promptly and delayed sending the patient, who may have been
having a heart attack, to the ED for 90 minutes. Even after the provider ordered the nurse to
transfer the patient to the ED, the nurse waited an additional 23 minutes before calling 9-1-1.
This placed the patient at risk of complications from the delayed evaluation of chest pain.
• In case 4, the patient overdosed on an unknown substance. The initial emergency response
was appropriate with medical staff administering naloxone with good results. However, the
on-call provider did not evaluate the patient properly. The patient needed more monitoring
because he could have been in danger when the naloxone wore off. The patient also needed
diagnostic testing to determine which drug the patient had taken and whether he had any
metabolic imbalances from the overdose. Unfortunately, the provider failed to examine the
patient, did not arrange the needed monitoring or testing, and inappropriately released the
patient back to regular housing. The patient overdosed again two days later.
• In case 5, the patient overdosed on heroin and was unconscious. First medical responders
began CPR because the patient had no pulse and was in respiratory distress. The nurse
incorrectly administered low-flow oxygen through the bag-valve-mask resuscitator. The
nurse should have administered high-flow oxygen in this situation. Fortunately, the patient
did not appear to suffer any harm from this error, and staff successfully resuscitated him.
• In case 6, the patient was unresponsive, not breathing, and without a pulse. Staff began CPR,
but failed to call 9-1-1 until they transported the patient to the TTA 20 minutes later, a
severe delay. PVSP staff delayed advanced cardiovascular life support (ACLS) measures
until outside paramedics arrived. Unfortunately, the ACLS efforts were unsuccessful, and
the patient died in the TTA.
• In case 8, the unresponsive patient had a self-inflicted leg wound. PVSP staff failed to call
9-1-1. Despite resuscitative measures, the patient died in the TTA due to the amount of
blood lost.
Provider Performance
Consistent with PVSP’s designation as a basic care institution, we reviewed relatively few
medical emergencies during the case review period. Most providers managed these encounters
via telephone consultation with the TTA nurse. Emergency provider performance at PVSP was
unreliable; we found six provider deficiencies, four of which were significant. As we noted
previously, providers made critical errors during the emergency responses in cases 2, 3, and 4.
Poor emergency provider performance is also illustrated in the case below:
• In case 15, the patient developed abdominal pain and bloody vomiting. The provider saw the
patient in the TTA and appropriately referred him to an outside ED. Unfortunately, the
provider gave the patient Toradol (a non-steroidal pain injection), which can increase the
risk of stomach bleeding. Because the patient already complained of vomiting blood, this
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 27
Office of the Inspector General State of California
pain medication was contraindicated. Fortunately, no harm came to the patient from the
provider’s error.
Nursing Performance
We found emergency nursing performance unreliable. As we previously noted, nurses made
critical errors during the emergency responses in cases 2, 3, 5, 6, and 8. PVSP nurses
demonstrated patterns of assessment and intervention errors that increased their patients’ risk of
harm. We found substandard nursing care in the following cases:
• In case 1, the nurse evaluated the patient urgently for seizures, but did not determine if the
patient had urinary incontinence.
• In case 2, nurses failed to assess if the patient had responded to the second dose of naloxone.
While in the TTA, nurses failed to monitor the patient’s level of consciousness for
37 minutes and never checked the patient’s blood pressure.
• In case 3, the nurse did not reassess the patient’s chest pain during the last 83 minutes the
patient was in the TTA.
• In case 17, the nurse did not reassess whether the patient’s chest pain had improved at the
time of his release from the TTA.
• In case 18, the TTA nurse evaluated the patient for an arm wound, but did not assess the
skin integrity or describe the wound’s size or appearance.
Nursing Documentation
Documentation is a serious responsibility, and nurses should include specific details of the care
provided, information conveyed to the patient, and the outcomes of the interventions. Nurses did
not meet this responsibility in several cases. The first medical responder and TTA RN notes were
missing or incomplete in the following cases:
• In case 4, the first medical responder did not document the administration of two doses of
naloxone to which the patient had responded.
• In case 6, staff found the patient unresponsive and with various injuries to the head and face.
The nurses recorded different timelines of the emergency care, recorded an incorrect type of
oxygen mask used, and entered two different dosages of medication administered. The
nurses also failed to document the injuries observed on the patient.
• In case 7, the nurses did not document the amount of oxygen applied and the time the
provider arrived in the TTA.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 28
Office of the Inspector General State of California
Emergency Medical Response Review Committee
We reviewed several Emergency Medical Response Review Committee (EMRRC) minutes. The
EMRRC did not identify the poor emergency responses, the poor provider and nurse
performances, or the inaccurate nursing documentation that we identified in our review.
Clinician Onsite Inspection
The TTA had two examination rooms with gurneys and medical supplies, and a third room with
a crash cart and an AED (automated external defibrillator). The rooms were equipped for cardiac
monitoring and emergency care. Two nurses staffed the TTA each shift, and a provider was also
present during the day shifts. The nurses were familiar with the chest pain protocol and could
recount the required processes. Nurses also processed patients returning from the hospital and
offsite specialty services. According to TTA staff, when they receive specialty reports, they
inform the provider and then scan the report into the electric medical record. The TTA supervisor
and staff reported positive morale.
Case Review Conclusion
PVSP medical staff performed poorly with regard to Emergency Services. Medical staff often
failed to provide appropriate life support for patients with medical emergencies. Staff provided
insufficient respiratory support and delayed calling 9-1-1. Both providers and nurses were
responsible for these critical errors. Furthermore, the EMRRC failed to identify important lapses
in care in these cases. Compared to Cycle 4, PVSP significantly declined in its quality of
emergency services. We rated this indicator inadequate.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 29
Office of the Inspector General State of California
HEALTH INFORMATION MANAGEMENT
Health information management is a crucial link in the delivery of
Case Review Rating:
medical care. Medical personnel require accurate information in Adequate
order to make sound judgments and decisions. This indicator Compliance Score:
examines whether the institution adequately manages its health care Proficient
(85.3%)
information. This includes determining whether the information is
correctly labeled and organized and available in the electronic Overall Rating:
medical record; whether the various medical records (internal and Adequate
external, e.g., hospital and specialty reports and progress notes) are
obtained and scanned timely into the patient’s electronic medical record; whether records routed
to clinicians include legible signatures or stamps; and whether hospital discharge reports include
key elements and are timely reviewed by providers.
For this indicator, the case review and compliance review processes yielded different results,
with the case reviewers assigning an adequate rating and the compliance testing resulting in a
proficient score. Our case review testing found frequent problems with the institution’s handling
of specialty reports. The institution failed to retrieve specialty reports or retrieved them late.
Fortunately, despite these problems, providers usually addressed the specialty recommendations
appropriately. Because the institution had room for improvement in this area, we determined that
the overall rating for this indicator was adequate.
During the OIG’s testing period, PVSP had converted to the new electronic health record system
(EHRS) in May 2017; therefore, most testing occurred in the EHRS, with a minor portion of the
testing done in the electronic unit health record (eUHR).
Case Review Results
We reviewed 743 events and found 20 deficiencies related to health information management. Of
those 20 deficiencies, 2 were significant. Although we identified some deficiency patterns,
patient care was unhindered in most cases. As a result, we rated this indicator adequate.
Hospital Records
We reviewed ten hospital or ED transfers. PVSP usually retrieved, scanned, and reviewed
hospital records timely. There was one significant deficiency:
• In case 3, the patient received care from an outside ED for chest pain. PVSP staff failed to
retrieve or review the outside ED physician report, placing the patient who was already at
high risk of cardiovascular disease at further risk of a lapse in care.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 30
Office of the Inspector General State of California
Specialty Services
We reviewed 37 specialty services encounters and identified 12 deficiencies. PVSP had
difficulty retrieving specialty reports on time, and providers often failed to sign those reports.
The institution did not retrieve specialty reports timely or at all in cases 8, 15, 17, 29, and 41.
The providers failed to sign specialty reports in cases 8 and 20. Fortunately, most providers
reviewed important specialty recommendations when they became available and communicated
these with their patients, even when they failed to sign the reports. We discuss these findings
further in the Specialty Services indicator.
Diagnostic Reports
PVSP did very well with its handling of diagnostic reports. We reviewed 97 events and identified
four deficiencies. Compared to Cycle 4, PVSP showed similar deficiency patterns related to
providers not signing the reports prior to the reports being scanning into medical records. We
found only one significant deficiency, which we also discuss in the Diagnostic Services
indicator.
Urgent/Emergent Records
Most deficiencies in this category resulted from poor nursing documentation, which we also
discuss in the Emergency Services indicator. In addition to the problems we already discussed,
we also found errors in the following cases:
• In case 2, the provider recorded that the patient required three doses of naloxone, but the
medical record showed no evidence the third dose was ordered or administered.
• In case 4, the first medical responder did not record the administration of two doses of
naloxone.
• In case 6, the medical records staff incorrectly scanned a TTA record into the EHRS as a
CTC encounter and used the incorrect date.
Scanning Performance
As in Cycle 4, we identified a pattern of minor deficiencies with misfiled and mislabeled
documents (cases 6, 13, 17, 20, and 35).
Legibility
After implementation of the EHRS, legibility at the institution improved. We did not have any
significant difficulty with document legibility.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 31
Office of the Inspector General State of California
Clinician Onsite Visit
PVSP had recently implemented the EHRS, prior to the start of our inspection; therefore, we
attribute some deficiencies to incomplete EHRS training. According to medical records staff,
providers were automatically notified of newly available reports through the EHRS message
center. However, we found a pattern in which providers did not sign their reports. Twelve of the
37 deficiencies related to specialty services. The institution delegated much of the specialty
report workflow to many different staff, and this fragmentation contributed to many missing or
delayed reports.
Case Review Conclusion
PVSP performed sufficiently with managing health information following the EHRS
implementation. However, we did find repeated problems with the institution’s processing of
specialty reports. We rated this indicator adequate.
Compliance Testing Results
The institution scored in the proficient range with a score of 85.3 percent in the Health
Information Management indicator. The following tests were proficient:
• PVSP timely scanned eight non-dictated progress notes, initial health screening forms, and
requests for health care services into the patients’ electronic medical records (MIT 4.001).
• PVSP timely scanned community hospital discharge reports into patients’ medical records
for all 20 sampled patients (MIT 4.004).
Two tests received adequate scores:
• PVSP scored 79.2 percent in its labeling and filing of documents scanned into patients’
electronic medical records. For this test, the OIG bases its score on 24 mislabeled or misfiled
documents; the institution mislabeled five documents (MIT 4.006).
• Providers reviewed 17 of 22 hospital discharge reports within three calendar days of the
patient’s discharge (77.3 percent). Providers reviewed four discharge reports from one to six
days late. For one final report, the provider did not review it at all (MIT 4.007).
One test received a score in the inadequate range:
• The institution timely scanned 14 of 20 sampled specialty service consultant reports into the
patients’ electronic health records (70.0 percent). The institution scanned six other specialty
reports from 2 to 22 days late (MIT 4.003).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 32
Office of the Inspector General State of California
HEALTH CARE ENVIRONMENT
This indicator addresses the general operational aspects of the
Case Review Rating:
institution’s clinics, including certain elements of infection control Not Applicable
and sanitation, medical supplies and equipment management, the Compliance Score:
availability of both auditory and visual privacy for patient visits, and Inadequate
(53.9%)
the sufficiency of facility infrastructure to conduct comprehensive
medical examinations. The OIG rates this component entirely on the Overall Rating:
compliance testing results from the visual observations inspectors Inadequate
make at the institution during their onsite visit. There is no case
review portion.
Compliance Testing Results
PVSP earned an inadequate compliance score of 53.9 percent in the Health Care Environment
indicator. The institution received scores in the inadequate range in the following seven tests:
• In only six of ten clinics inspected, clinical
health care staff ensured that reusable invasive
and non-invasive medical equipment was
properly sterilized or disinfected
(60.0 percent). In the other four clinics, one or
more of the following deficiencies were
identified: clinical staff failed to mention
disinfecting the examination table prior to the
start of a shift as part of their daily protocol;
clinical staff failed to describe the proper
sterilization process of reusable medical
equipment; the clinic stored previously
sterilized medical equipment beyond the
Figure 2: Expired medical supplies
indicated shelf life; and clinical staff did not
replace the disposable paper on the examination table between patient encounters (Figure 2)
(MIT 5.102).
• We observed clinician encounters with patients in ten clinics. Clinicians followed good hand
hygiene practices in six clinics (60.0 percent). At four other clinic locations, clinicians failed
to wash their hands before and after patient contact (MIT 5.104).
• Health care staff at four of the ten clinics followed proper protocols to mitigate exposure to
bloodborne pathogens and contaminated waste (40.0 percent). Six other clinics did not have
puncture-resistant containers in examination rooms for medical staff to discard expended
needles and sharps (MIT 5.105).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 33
Office of the Inspector General State of California
• The non-clinic bulk medical supply storage areas did not meet the supply management
process or support the needs of the medical health care program. Medical supplies were
stored directly on the floor. As a result, the institution scored zero on this test (MIT 5.106).
• Only three of the ten clinics inspected
followed adequate medical supply storage
and management protocols
(30.0 percent). In the seven other clinics,
one or more of the following deficiencies
were identified: clinics stored medical
supplies beyond manufacturers’
guidelines; medical supplies were
inappropriately stored together with
personal items and germicidal wipes;
personal food items were stored long
term in the bulk medical supply room; Figure 3: Personal belongings and food
and medical supply cabinets were stored in the same area as medical supplies
disorganized and their contents not
clearly identifiable (Figure 3) (MIT 5.107).
• Only two of ten clinic locations (20.0 percent) maintained core equipment or other essential
supplies necessary to conduct comprehensive examinations in their examination rooms and
common clinic areas. In eight other clinic locations, deficiencies in equipment and supplies
included one or more of the following: a demarcation line for the Snellen eye examination
chart was missing; there were no hemoccult cards and developer; a nebulization unit did not
have current calibration stickers or was missing; an oto-ophthalmoscope was missing; there
were no disposable paper covers for examination tables; there were no biohazard waste
durable receptacles or labeled plastic bags; tongue depressors were missing; and the weight
scale, AED, and pulse oximeters were missing current calibration stickers (MIT 5.108).
• Only five of ten clinic examination rooms observed (50.0 percent) had appropriate space,
configuration, supplies, and equipment to allow clinicians to perform a proper clinical
examination. Five other clinics had one or more of the following deficiencies: examination
room furniture was in disrepair; the examination room did not have adequate space to
perform patient examinations; and clinical areas did not have portable screens to provide
visual privacy (MIT 5.110).
Three tests received scores in the adequate range:
• Eight of the ten clinic locations inspected (80.0 percent) had operable sinks and sufficient
quantities of hand hygiene supplies in the examination areas. One clinic’s examination room
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 34
Office of the Inspector General State of California
did not have antiseptic soap. Another clinic’s patient restroom did not have antiseptic soap
or disposable hand towels (MIT 5.103).
• Clinic common areas at seven of the nine clinics (77.8 percent) had environments conducive
to providing medical services. In two other clinics, the location of triage stations
compromised patients’ auditory privacy (MIT 5.109).
• We examined emergency medical response bags (EMRBs) and crash carts to determine if
the institution staff inspected them daily and inventoried them monthly, and whether they
contained all essential items. At six of the eight applicable clinical locations (75.0 percent),
EMRBs and crash carts were compliant. At two locations, staff did not inventory the
minimum levels of medical supplies in the crash carts (MIT 5.111).
One test received a score in the proficient range:
• Staff appropriately disinfected, cleaned, and sanitized all ten sampled clinics (MIT 5.101).
Non-Scored Results
We gathered information to determine if the institution maintained its physical infrastructure in a
manner that supported health care management’s ability to provide timely or adequate health
care. We do not score this question.
• When we interviewed health care managers, they had no concerns about the facility’s
infrastructure or its effect on the staff’s ability to provide adequate health care. However, at
the time of our medical inspection, PVSP had several significant infrastructure projects
under way. These projects included increasing space at four yards, renovation of specialty
clinics, and creating new space for the ambulatory surgical unit, TTA, pharmacy, and
laboratory. These projects were started in the summer of 2016, and the institution estimated
that they would be complete by the spring of 2019 (MIT 5.999).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 35
Office of the Inspector General State of California
INTER- AND INTRA-SYSTEM TRANSFERS
This indicator focuses on the management of patients’ medical needs
Case Review Rating:
and continuity of patient care during the inter- and intra-system Inadequate
transfer process. The patients reviewed for this indicator include Compliance Score:
those received from, as well as those transferring out to, other CDCR Adequate
(83.8%)
institutions. The OIG review includes evaluation of the institution’s
ability to provide and document health screening assessments, Overall Rating:
initiation of relevant referrals based on patient needs, and the Inadequate
continuity of medication delivery to patients arriving from another
institution. For those patients, the OIG clinicians also review the timely completion of pending
health appointments, tests, and requests for specialty services. For patients who transfer out of
the institution, the OIG evaluates the ability of the institution to document transfer information
that includes preexisting health conditions, pending appointments, tests and requests for specialty
services, medication transfer packages, and medication administration prior to transfer. The OIG
clinicians also evaluate the care provided to patients returning to the institution from an outside
hospital and check to ensure appropriate implementation of the hospital assessment and
treatment plans.
For this indicator, the case review and compliance review processes yielded different results,
with the case reviewers assigning an inadequate rating and the compliance testing resulting in an
adequate score. Our case review testing found pervasive problems with the continuity of care for
patients transferring into and out of PVSP, as well as for those patients returning from a
community hospital. Lapses in care due to these problems were common and increased the risk
of patient harm. Therefore, we determined that the overall rating for this indicator was
inadequate.
Case Review Results
We reviewed 25 inter- and intra-system transfer cases, including information from both the
sending and receiving institutions. These included 12 hospitalization and outside emergency
room cases, each resulting in a transfer back to the institution. We found 20 deficiencies, of
which 8 were significant (cases 1, 3, 13, 14, 15, 27, and 28). The case review rating for this
indicator was inadequate.
Transfers In
When a new patient transfers into the institution, the R&R nurse should review any pending
appointments and notify the primary care team of the new arrival. The primary care team
provider should discuss the new patient in the morning huddle and schedule the follow-up
appointment with the provider and the nurse care coordinator. The provider should also reconcile
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 36
Office of the Inspector General State of California
and order appropriate medications. We reviewed six transfer-in cases and found several
problems with the transfer-in process:
• In case 1, the patient with a history of seizures transferred into PVSP. Even though the
R&R nurse saw the patient during normal business hours, the nurse failed to timely notify a
provider regarding the patient’s seizure medications. The nurse also failed to ensure
continuity of the patient’s other essential medications. Partially due to the nurse’s errors, the
patient experienced a lapse in medication continuity and developed seizures two days after
he arrived, requiring health care staff to send the patient to an outside ED. We also discuss
this case in the Pharmacy and Medication Management indicator.
• In case 6, the patient returned to the institution from an outside court appointment. The
patient should have received his prescribed medication when he arrived. The nurse
erroneously recorded that the patient was still outside the institution and failed to administer
the medication.
• In case 25, the patient arrived at PVSP and should have received a routine provider
appointment within 30 days of arrival. This appointment did not occur within the required
time frame.
Transfers Out
When a patient transfers out of the institution to another CDCR institution, the R&R nurse
should review the patient transfer summary, perform a face-to-face evaluation to ensure the
patient is stable for transfer, ensure that the patient has a five-day supply of medications, record
all pending appointments, and ensure that the patient’s durable medical equipment travels with
the patient. We reviewed seven transfer-out cases and identified four deficiencies:
• In case 1, the R&R nurse did not record the patient’s pending need for special shoes or the
patient’s history of seizures.
• In cases 13 and 27, the R&R nurse did not send the patients with a supply of their
medications when transferring them to other institutions.
• In case 28, the R&R nurse did not record why the patient needed his arm sling or the
patient’s activity restrictions.
Hospitalizations
Patients returning from hospitalizations are some of the highest-risk encounters due to two
factors. First, these patients usually require hospitalization for a severe illness or injury. Second,
they are at risk due to potential lapses in continuity of care that can occur during any transfer.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 37
Office of the Inspector General State of California
The TTA nurse evaluates patients returning from the community hospital and consults with a
provider after reviewing patient hospital discharge recommendations for follow-up care. We
reviewed 12 of these events and found 12 deficiencies. The following are examples of the
problems we found with the hospital-return process:
• In case 3, the physician’s report from the outside ED was not retrieved or reviewed.
• In case 13, the patient returned from the hospital after being treated for bleeding in the brain.
PVSP staff did not administer his hospital-recommended medications until three days after
he returned. This was a significant lapse in medication continuity.
• In case 14, the patient returned from the hospital after being treated for gastrointestinal
bleeding. The hospital physician recommended that the patient stop taking aspirin, a blood
thinner that can cause intestinal bleeding. Although the provider discontinued the
medication, the nurse did not instruct the patient to stop taking the aspirin. The patient
continued taking the medication for three weeks. Fortunately, the patient did not suffer any
harm. We also discuss this case in the Quality of Nursing Performance indicator.
• In case 15, the patient returned from the hospital and did not receive the newly
recommended medication until two days after he returned. The patient was also on several
chronic medications and did not receive them until one and two months later.
• In case 16, the patient returned from the hospital with a recommendation to continue
antibiotics. The patient missed an antibiotic dose the day after he returned, increasing the
risk for infection complications.
• In case 28, the patient returned from the hospital with a pacemaker. The hospital provider
called the institution to transmit discharge instructions, which included a cardiology
follow-up appointment two weeks after hospital discharge. When the patient returned from
the hospital, the provider failed to order the cardiology follow-up appointment, which did
not occur.
Clinician Onsite Inspection
The R&R was sufficiently staffed, with a nurse assigned to each shift. The R&R nurse appeared
knowledgeable about the transfer processes and reported that staff evaluated newly arrived
patients and sent the patients to the TTA if their conditions warranted further intervention. The
nurse also stated that the clinic’s primary care teams scheduled required follow-up appointments.
According to the nurse, if the patients did not bring their medications with them the morning of
their transfer, the nurses would transfer the patients to other institutions without their
medications. When this problem occurred, the R&R nurse would notify the receiving institution
of the missing medications. Furthermore, the nurse explained, the PVSP pharmacy routinely did
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 38
Office of the Inspector General State of California
not provide the required five-day supply of medications for patients transferring out of the
institution.
The TTA nurse reported that staff in the TTA evaluated patients returning from the outside
hospital or ED. The nurse would call the outside facility to obtain the discharge report if the
facility failed to send it with the patient. If the TTA nurse could not get the report, then it became
the responsibility of medical records staff to obtain the missing report. Regarding medications,
the nurse notified a provider, who was then responsible for ordering all the patient’s medications.
The TTA nurse might order a follow-up appointment for a patient in the EHRS, but the clinic’s
primary care team was responsible for discussing the patient in the morning huddles and
scheduling the follow-up appointment at that time. According to the nurse, the institution did not
have any on-call pharmacists on the weekends, so the nurses were often incapable of
administering new medications until the pharmacist returned during regular business hours.
Case Review Conclusion
The institution demonstrated fundamental problems with many aspects of the transfer process.
PVSP had difficulty ensuring medication continuity for patients transferring into the institution.
When patients transferred to other CDCR institutions, PVSP’s nurses often did not list important
medical information on the transfer forms, and the nurses reported that they regularly failed to
provide the required five-day supply of medications needed to ensure medication continuity. For
patients returning from an outside hospital, a variety of errors occurred, including poor
medication continuity, insufficient nurse assessment and education, and inconsistent health
information transmittal. We discussed these issues with the institution’s nursing administrative
team, who acknowledged the findings. Because of these various problems that increased the risk
of patient harm, we rated this indicator inadequate.
Compliance Testing Results
The institution scored in the adequate range for this indicator, with a score of 83.8 percent, with
proficient scores on the following tests:
• Nursing staff completed an initial health screening form on the same day the patient arrived
for 24 of 25 patients who transferred into PVSP from another CDCR institution
(96.0 percent). For one patient, nursing staff did not document the patient’s weight
(MIT 6.001).
• The nursing staff timely completed the assessment and disposition sections of the screening
form for all 25 patients (MIT 6.002).
• We inspected the transfer packages of two patients who were transferring out of the facility
to determine whether the packages included required medications and support
documentation. Both transfer packages were compliant (MIT 6.101).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 39
Office of the Inspector General State of California
One test received a score in the adequate range:
• Nursing staff timely delivered or administered medications to eight of the ten patients who
transferred into PVSP with an existing medication order that required its administration at
the next dosing interval after the patients’ arrival (80.0 percent). For two patients, nursing
staff delivered or administered their medications two and three days late (MIT 6.003).
One test received an inadequate score:
• For 6 of 14 sampled patients who transferred out of PVSP to another CDCR institution
(42.9 percent), nursing staff documented their pending specialty service appointments on the
patients’ health care transfer forms. For six other patients, nursing staff did not document
their pending appointments on the transfer forms. For the remaining two patients, nursing
staff did not complete a health care transfer form (MIT 6.004).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 40
Office of the Inspector General State of California
PHARMACY AND MEDICATION MANAGEMENT
This indicator is an evaluation of the institution’s ability to provide
Case Review Rating:
appropriate pharmaceutical administration and security management, Inadequate
encompassing the process from the written prescription to the Compliance Score:
administration of the medication. By combining both a quantitative Inadequate
(63.1%)
compliance test with case review analysis, this assessment identifies
issues in various stages of the medication management process, Overall Rating:
including ordering and prescribing, transcribing and verifying, Inadequate
dispensing and delivering, administering, and documenting and
reporting. Because numerous entities across various departments affect medication management,
this assessment considers internal review and approval processes, pharmacy, nursing, health
information systems, custody processes, and actions taken by the prescriber, staff, and patient.
Case Review Results
We evaluated 69 events related to medications and found 29 deficiencies. We identified
18 significant lapses in medication delivery. The case review rating for this indicator was
inadequate.
Medication Continuity
The institution demonstrated a pattern of delays or failures in refilling chronic medications,
obtaining new medications following hospitalization, and sending medications with the patient
when transferring to another institution. We found these deficiencies in cases 5, 6, 19, 27, and
in the following cases:
• In case 1, the patient with a history of seizures transferred into PVSP. The R&R nurse failed
to timely notify a provider regarding the patient’s medications, contributing to the lapse in
medication continuity. The following day, the provider ordered the seizure medications to
begin the same day, but PVSP did not follow the provider’s orders and failed to provide the
patient with the medications. On the third day after the patient arrived at PVSP, the patient
developed seizures and had to be sent to an outside ED. We also discussed this case in the
Inter- and Intra-System Transfers indicator.
• In case 3, the patient requested refills of his high-cholesterol, allergy, and asthma
medications. The patient received one of the medications one month late and did not receive
the other medications at all.
• In case 13, the patient had bleeding in his brain and was hospitalized. When the patient
returned to PVSP, staff admitted him to the CTC, but failed to obtain the medications
recommended by the hospital. The patient did not receive the medications until three days
later. Staff discharged the patient back to regular housing. The patient did not receive his
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 41
Office of the Inspector General State of California
gout medication until a month later. When the patient transferred to another CDCR
institution, the pharmacy failed to send a five-day supply of his medications with him.
• In case 14, the patient requested refills of calcium-vitamin D (prescribed to control tremors
from other mental health medications), asthma inhalers, and antacid medications. He
received the calcium-vitamin D 12 days late and an inhaler 9 days late. The patient did not
receive the other inhaler and antacid medication.
• In case 15, the patient returned from the hospital and received his new medication two days
late. Also, the TTA nurse failed to obtain an order for the patient’s chronic blood pressure
medication, and the patient did not receive it until a month later. On another occasion, the
medication nurse noted the blood pressure medication was unavailable but did not ask the
pharmacy to dispense it. The patient did not receive the blood pressure medication until the
following month.
• Also in case 15, the provider reordered an essential antifungal medication for the patient’s
chronic coccidioidomycosis (valley fever) infection. The pharmacist canceled the order and
did not notify the provider. The patient did not receive the medication, which was a
significant lapse in care.
Medication Administration
The nurses usually administered medications timely. However, when a prescribed medication
expired or was not available, the nurses failed to contact the provider to renew the medication or
the pharmacy to dispense the medication, resulting in a break in medication continuity. Also,
medication nurses failed to administer medications or record the medications they gave to
patients in cases 1, 4, 5, 6, 14, and 16. The nurse erroneously administered an extra dose of the
patient’s medications twice in case 19.
Clinician Onsite Inspection
PVSP implemented the EHRS during the OIG inspection period. Inadequate training on the new
system resulted in providers being unaware of their responsibility to assure medication continuity
upon patients’ returning to PVSP. Nurses also failed to ensure medication continuity by
neglecting to obtain critical medication orders or administer essential medications during the
transitions of care that occur when patients transfer into or out of the institution. Furthermore,
PVSP had no PIC for several months. This absence may have also contributed to PVSP’s poor
medication performance during this crucial EHRS transition time. When our clinicians visited
PVSP in May 2018, the pharmacy department remained understaffed, and there was no weekend
pharmacist available to help resolve any medication issues, even urgent or emergent ones.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 42
Office of the Inspector General State of California
Case Review Conclusion
PVSP performed poorly in several areas of Pharmacy and Medication Management. Medication
continuity was poor for PVSP patients who transferred into or out of the institution and for those
patients who returned from an outside hospital. Also, nurses failed to ensure medication
continuity for patients by failing to obtain necessary medication orders or intervening when
medications were not available. The pharmacy also failed to dispense needed medications,
especially on the weekends when there was no pharmacist available. We rated this indicator
inadequate.
Compliance Testing Results
The institution received an inadequate compliance score of 62.8 percent in the Pharmacy and
Medication Management indicator. For discussion purposes below, this indicator is divided into
three sub-indicators: medication administration, observed medication practices and storage
controls, and pharmacy protocols.
Medication Administration
In this sub-indicator, the institution received an adequate score of 76.7 percent. One test earned a
score in the proficient range:
• Nursing staff administered medications without interruption to 23 of 25 applicable patients
who transferred from one housing unit to another (92.0 percent). For two patients, nursing
staff did not document the reason for the patient’s refusal of the medication (MIT 7.005).
One test earned a score in the adequate range:
• Nursing staff timely administered or delivered newly ordered medications to 20 of the
25 sampled patients (80.0 percent). For four patients, nursing staff administered their
medications one day late. For one final patient, nursing staff did not administer the
medication at all (MIT 7.002).
Two tests earned scores in the inadequate range:
• Nursing staff timely administered chronic care medications to 10 of 15 applicable patients
(66.7 percent). For two patients, nursing staff delivered keep-on-person (KOP) medications
two days late. For three other patients, PVSP replenished multiple supplies of chronic care
medications in a shorter duration than normal. In addition, for three of the six patients who
did not receive timely mediations, the institution did not make available KOP medications at
least one business day prior to exhaustion (MIT 7.001).
• The institution timely provided newly ordered medications to 15 of 22 applicable patients
(68.2 percent). For five patients, nursing staff did not administer one to two doses of their
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 43
Office of the Inspector General State of California
medications. For another patient, PVSP had his ordered medication available three days late.
For one final patient, the provider did not order his medications within eight hours of his
arrival to the institution (MIT 7.003).
Observed Medication Practices and Storage Controls
The institution received an inadequate score of 60.0 percent in this sub-indicator. The following
tests scored in the inadequate range:
• The institution properly employed security controls over narcotic medications in four of the
seven applicable clinic and medication line locations where narcotics were stored
(57.1 percent). At three clinics, the narcotics logbook showed that a controlled substance
inventory was not performed by two licensed nursing staff on multiple occasions
(MIT 7.101).
• PVSP safely stored non-refrigerated, non-narcotic medications in only two of the eight
applicable clinic and medication line storage locations (25.0 percent). In six other locations,
one or more of the following deficiencies were observed: the medication area lacked a
designated area for return-to-pharmacy medications; oral and topical medications were not
properly separated when stored; medication rooms and cabinets were disorganized;
multi-use medication was not labeled with the date it was opened; medication was stored
beyond its expiration date; and the pharmacist did not perform an inventory of crash cart
medication within the last 30 days (MIT 7.102).
• Non-narcotic refrigerated medications were properly stored at four of the nine applicable
clinic and medication line storage locations (44.4 percent). In five other locations, one or
more of the following deficiencies were observed: staff did not complete temperature
logbooks; refrigerator temperatures were not kept within an acceptable range; the
medication area lacked a designated area for return-to-pharmacy refrigerated medications;
and medications were stored beyond manufacturers’ guidelines (MIT 7.103).
• Only three of six inspected medication preparation and administration areas demonstrated
appropriate administrative controls and protocols (50.0 percent). At two other locations,
medication nurses did not always ensure patients swallowed direct observation therapy
(DOT) medications. One other medication line location did not have sufficient outdoor
cover to protect patients waiting to receive their medications from heat or inclement weather
(MIT 7.106).
One test received an adequate score:
• Nursing staff at five of the six sampled medication preparation and administration locations
(83.3 percent) followed proper hand hygiene and contamination control protocols during the
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 44
Office of the Inspector General State of California
medication preparation and administrative processes. At one location, not all nursing staff
washed or sanitized their hands before reapplying gloves (MIT 7.104).
One test received a proficient score:
• Nursing staff at all six inspected medication line locations employed proper administrative
controls and followed appropriate protocols during medication preparation (MIT 7.105).
Pharmacy Protocols
PVSP received an inadequate score of 56.0 percent in this sub-indicator. The institution earned
inadequate scores in the tests below:
• In its main pharmacy, PVSP did not properly store non-refrigerated medication, and
medication boxes were stored directly on the floor of the pharmacy. In addition, personal
beverages belonging to staff were kept in the medication preparation areas, resulting in a
score of zero for this test (MIT 7.108).
• The main pharmacy did not properly store refrigerated or frozen medications. The pharmacy
stored medications beyond manufacturers’ guidelines, resulting in a score of zero for this
test (MIT 7.109).
The following test received an adequate score:
• The institution’s PIC followed required protocols for 20 of the 25 medication error reports
and monthly statistical reports reviewed (80.0 percent). For five medication error reports, the
PIC completed corresponding medication error follow-up reports from one to 36 days late
(MIT 7.111).
The following tests were proficient:
• In its main pharmacy, the institution followed general security, organization, and cleanliness
management protocols (MIT 7.107).
• The PIC properly accounted for narcotic medications stored in PVSP’s pharmacy and
reviewed monthly inventories of controlled substances in PVSP’s clinical and medication
line storage locations (MIT 7.110).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 45
Office of the Inspector General State of California
Non-Scored Tests
• In addition to our testing of reported medication errors, we follow up on any significant
medication errors found during compliance testing to determine whether PVSP properly
identified and reported errors. We provide those results for information purposes only. At
PVSP, we did not find any applicable medication errors (MIT 7.998).
• We interviewed patients housed in isolation units to determine whether they had immediate
access to their prescribed KOP rescue inhalers and nitroglycerin medications. Three of four
applicable patients interviewed indicated they had access to their rescue medications. One
patient indicated that he did not have his inhaler with him. Upon notification, PVSP took
timely action to replace the patient’s inhaler (MIT 7.999).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 46
Office of the Inspector General State of California
PRENATAL AND POST-DELIVERY SERVICES
This indicator evaluates the institution’s capacity to provide timely
Case Review Rating:
and appropriate prenatal, delivery, and postnatal services to pregnant
Not Applicable
patients. This includes the ordering and monitoring of indicated
Compliance Score:
screening tests, follow-up visits, referrals to higher levels of care,
Not Applicable
e.g., high-risk obstetrics clinic, when necessary, and postnatal
Overall Rating:
follow-up.
Not Applicable
As PVSP does not have female patients, this indicator does not
apply.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 47
Office of the Inspector General State of California
PREVENTIVE SERVICES
This indicator assesses whether the institution offered or provided
Case Review Rating:
various preventive medical services to patients. These include cancer Not Applicable
screenings, tuberculosis screenings, and influenza and chronic care Compliance Score:
immunizations. This indicator also assesses whether certain Proficient
(88.2%)
institutions take preventive actions to relocate patients identified as
being at higher risk for contracting coccidioidomycosis Overall Rating:
(valley fever). Proficient
The OIG rates this indicator entirely through the compliance testing component; the case review
process does not include a separate qualitative analysis for this indicator.
Compliance Testing Results
The institution scored in the proficient range for this indicator at 88.2 percent. The following
four tests were in the proficient range:
• Nursing staff performed monthly or weekly monitoring for all 12 patients who were taking
tuberculosis (TB) medications (MIT 9.002).
• During the most recent influenza season, the institution timely provided or offered all
25 patients an influenza vaccination (MIT 9.004).
• The institution offered annual colorectal cancer screenings to 24 of 25 applicable patients
(96.0 percent). One patient did not have a normal colonoscopy and was not offered a
colorectal cancer screening within the previous 12 months (MIT 9.005).
• We tested whether the institution offered vaccinations for influenza, pneumonia, and
hepatitis to patients who suffered from chronic care conditions. The institution offered or
provided 14 of 15 applicable patients vaccinations (93.3 percent). For one patient, there was
no evidence he was offered hepatitis A and B vaccinations (MIT 9.008).
Two tests received adequate scores:
• We sampled 30 patients at PVSP to determine whether they received a TB screening within
the last year and during the month of their birth; 23 of the 30 patients sampled (76.7 percent)
timely received the screening. For seven patients, the institution did not conduct the
TB screening in the patient’s birth month (MIT 9.003).
• The institution timely transferred 17 of 20 patients (85.0 percent) who were deemed at high
risk for contracting the coccidioidomycosis infection, and identified as medically restricted
and ineligible to reside at PVSP. The institution transferred the remaining three patients out
of PVSP from 18 to 53 days late (MIT 9.009).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 48
Office of the Inspector General State of California
One test was inadequate:
• Nursing staff timely administered TB medications to 8 of the 12 applicable patients
(66.7 percent). For three patients, nursing staff did not administer their medications at the
provider-scheduled interval dates. For the remaining patient, nursing staff administered the
wrong dosage for one of the patient’s TB medications (MIT 9.001).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 49
Office of the Inspector General State of California
QUALITY OF NURSING PERFORMANCE
The Quality of Nursing Performance indicator is a qualitative
Case Review Rating:
evaluation of the institution’s nursing services. The evaluation is
Inadequate
completed entirely by OIG nursing clinicians within the case review
Compliance Score:
process and does not have a score under the OIG compliance testing
Not Applicable
component. Case reviews include face-to-face encounters and
Overall Rating:
indirect activities performed by nursing staff on behalf of the patient.
Inadequate
Review of nursing performance includes all nursing services
performed onsite, such as outpatient, inpatient, urgent/emergent,
patient transfers, care coordination, and medication management. The key focus areas for
evaluation of nursing care include appropriateness and timeliness of patient triage and
assessment, identification and prioritization of health care needs, use of the nursing process to
implement interventions, and accurate, thorough, and legible documentation. Although the OIG
reports nursing services provided in specialized medical housing units in the Specialized Medical
Housing indicator, and those provided in the TTA or related to emergency medical responses in
the Emergency Services indicator, this Quality of Nursing Performance indicator summarizes all
areas of nursing services.
Case Review Results
We reviewed 241 nursing encounters, 148 of which were in the outpatient setting. Most
outpatient nursing encounters were for sick call requests, walk-in visits, and nurse follow-up
appointments. In all, we identified 60 deficiencies related to nursing care performance, 14 of
which were significant. The most important nurse deficiencies we found were in emergency
services, sick call, and transfers. We rated the Nursing Performance indicator inadequate.
Nursing Sick Call
We found widespread problems with the nursing sick call performance at PVSP. When sick call
nurses assessed their patients, they often made poor or incomplete assessments. They also did not
consistently intervene correctly or timely refer sick patients to a provider. We found one or more
deficiencies with nursing sick call performance in cases 1, 3, 13, 14, 15, 29, 30, 31, 34, 35, 36,
38, 40, and 41. The following are a few examples of poor nursing sick call performance:
• In case 13, the patient was shivering, had a bad headache, was vomiting, and had elevated
blood pressure and heart rate. The patient had warning signs and symptoms of an impending
or current serious neurological condition, but the nurse did not recheck the patient’s
abnormal vital signs or contact a provider. Instead, the nurse ordered a routine provider
follow-up appointment and sent the patient back to his housing unit with the unresolved
symptoms. The following day, the patient submitted another sick call request for a recurring
headache. The nurse found the patient with persistently elevated blood pressure and
contacted a provider. The provider ordered the patient another blood pressure check later
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 50
Office of the Inspector General State of California
that afternoon, but the nurses failed to do the check. On the third day, the patient developed
a sudden loss of vision and had persistent vomiting, uncontrolled blood pressure, and an
explosive headache. The provider intervened, examined the patient, and sent the patient to
an offsite hospital. Hospital physicians diagnosed the patient with a bleeding brain aneurysm
and performed extensive life-saving surgery.
• In case 29, the patient had fallen the day before and had a swollen, discolored, and painful
knee. The nurse did not notify the provider of the patient’s fall. Also, the nurse did not offer
the patient any education for fall prevention or offer an assistive device to minimize the risk
of another fall. Furthermore, the nurse failed to record a time frame for the provider referral
or whether the patient was using a brace or a cane. The nurse’s errors placed the patient at
further risk of injury. Fortunately, a provider saw the patient three days later.
• In case 36, the patient submitted a sick call request for worsening chills, cough, fatigue, and
night sweats. The nurse should have made a same-day or urgent referral to a provider, but
instead made a routine referral. Fortunately, the provider was able to diagnose and treat the
patient’s valley fever, and the delay did not result in harm.
• In case 40, the patient fell in his cell and submitted a sick call request for a severe headache.
The sick call nurse did not inquire as to how or why the patient fell or attempt to determine
if the patient may have had a seizure or other condition that could have precipitated the fall.
Outpatient Nursing
Aside from the sick call, we found that nurses occasionally neglected to perform some tasks or
made poor decisions. Examples of these errors included failing to provide sufficient wound care
or to notify a provider when their patients required medical expertise. PVSP can use the
following examples for quality improvement:
• In case 14, the patient returned from a hospitalization for gastrointestinal bleeding and saw
the nurse. The nurse did not review the hospital report or the primary provider’s hospital
follow-up progress note. The nurse was unaware of the patient’s recent medication changes.
The nurse did not discuss with a provider the plan to stop certain important medications to
prevent bleeding recurrence. We also discuss this case in the Inter- and Intra-System
Transfers indicator.
• In case 12, on two occasions, the provider ordered blood pressure checks once a day. For
both orders, nurses failed to check the patient’s blood pressure multiple times.
Wound care errors occurred in cases 16, 44, and the following case:
• In case 18, the patient saw the nurse for a draining wound on his arm. The nurse described
the wound with five open, draining areas, and a foul smell. The nurse cleaned and dressed
the wound, but did not notify the nursing supervisor, the TTA nurse, or a provider of the
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 51
Office of the Inspector General State of California
severity of the wound. This clinical decision by the nurse placed the patient at risk for
further complications. The next day, the patient had to be sent to the hospital for a rapidly
spreading bacterial skin infection.
• In case 19, the patient was being treated for a wound infection with antibiotics. The nurse
evaluated the patient’s wound and discovered that the wound was worsening. The nurse did
not notify the nurse supervisor or the provider of the changes in the wound’s condition,
resulting in a delay in care. Fortunately, a provider examined the wound the following day
and sent the patient to an offsite hospital because the wound was not responding to
antibiotics.
We also found that PVSP nurses did not provide sufficient patient education in cases 3, 6, 29, 33,
and 38, and made documentation errors in cases 5, 29, and 41.
Urgent/Emergent Care
We reviewed 25 urgent or emergent encounters and found 10 nursing deficiencies, 6 of which
were significant. The emergency nursing performance at PVSP was unreliable. We found errors
made by first medical responders and TTA nurses that increased the patients’ risk of harm. Refer
to the Emergency Services indicator for additional details regarding nursing performance in this
area.
Care Management
In each clinic, PVSP nurse supervisors assigned a licensed vocational nurse (LVN) as a care
coordinator. For chronic care management, the care coordinators were supposed to monitor the
CCHCS patient registry, identify patients with poorly controlled chronic conditions, ensure
appropriate follow-up appointments were made, and provide education on chronic conditions to
patients. We found scant evidence of effective chronic care management, as we did not see any
such interventions for chronic care patients in the cases we reviewed.
Specialty Services
PVSP nurses usually provided sufficient care for patients in need of specialty services. We
reviewed 18 nursing encounters related to specialty services and found five deficiencies, two of
which were significant. Refer to the Specialty Services indicator for more details.
Specialized Medical Housing
The institution’s nurses provided high-quality care for patients in the CTC. We reviewed
77 nursing encounters in the CTC and found only two minor deficiencies. Refer to the
Specialized Medical Housing indicator for more information regarding nursing performance in
this area.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 52
Office of the Inspector General State of California
Inter-and Intra-System Transfers
PVSP nurses performed poorly with patients transferring into or out of the institution, and for
patients returning to PVSP from an offsite hospital. For patients transferring into PVSP, nurses
did not ensure medication continuity. For patients transferring out of PVSP, nurses did not
sufficiently record the patients’ needs or send the patients with a sufficient supply of
medications. For patients returning to PVSP from an offsite hospital, nurses again often failed to
ensure medication continuity. Refer to the Inter and Intra-System Transfers indicator for
additional details.
Clinician Onsite Inspection
We visited several clinical areas and interviewed various nursing staff, including registered
nurses, medication nurses, provider support nurses, and care coordinators. During the time of our
clinicians’ onsite visit, PVSP’s CTC was closed due to construction and repairs. In the short-term
restricted housing unit, we interviewed a psychiatric technician. The sick call nurse saw five to
nine patients on an average day. According to the nurses, there was no backlog for nurse
appointments. All the staff interviewed said they communicated with their nursing supervisors
daily. Overall, they reported positive morale at PVSP.
Case Review Conclusion
In the cases we reviewed, PVSP nurses performed well in the CTC and functioned satisfactorily
in specialty services. However, we found poor and unreliable nurse performance in emergency
services, sick call, care management, transfers, and hospital returns. Because nurse performance
in those areas increased the risk of patient harm, we rated the Quality of Nursing Performance
indicator inadequate.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 53
Office of the Inspector General State of California
QUALITY OF PROVIDER PERFORMANCE
In this indicator, the OIG physicians provide a qualitative evaluation
Case Review Rating:
of the adequacy of provider care at the institution. The case review
Inadequate
clinicians review the provider care regarding appropriate evaluation,
Compliance Score:
diagnosis, and management plans for programs including, but not
Not Applicable
limited to, nursing sick call, chronic care programs, TTA, specialized
Overall Rating:
medical housing, and specialty services.
Inadequate
OIG physicians alone assess provider care. There is no compliance
testing component associated with this quality indicator.
Case Review Results
We reviewed 22 cases which yielded 172 medical provider encounters. We identified
21 deficiencies related to provider performance, 8 of which were significant. Most deficiencies
occurred in emergency care, a vital area of importance. For the 22 in-depth cases reviewed, we
assigned the following ratings: one proficient, 14 adequate, and 7 inadequate. The case review
rating for the Quality of Provider Performance indicator was inadequate.
Assessment and Decision-Making
The institution’s providers demonstrated frequent errors in assessment and decision-making with
respect to urgent or emergent situations. These errors often increased the risk of lapses in care
and patient harm. We found these errors in cases 1, 12, 15, 21, 38, and in the following cases:
• In case 2, the patient had a critically low oxygen level during an emergency situation. When
the patient arrived at the TTA, the provider inappropriately ordered the nurses to change the
oxygen delivery to a less efficient method and to decrease the amount of oxygen delivered to
the patient, even though the patient had persistent and severely low oxygen levels. With
oxygen levels this low, the provider’s errors placed the patient at elevated risk for
irreversible brain and organ damage. Fortunately, the errors did not appear to result in any
permanent harm. We also discussed this case in the Emergency Services indicator.
• In case 3, the patient was at high risk for cardiac disease and developed symptoms
suggestive of a heart attack. The provider delayed sending the patient to the ED for
90 minutes, increasing the risk of irreversible heart damage and other cardiac complications.
We also discussed this case in the Emergency Services indicator.
• In case 4, the patient overdosed on an unknown substance. The initial emergency response
was appropriate with medical staff administering naloxone with good results. However, the
on-call provider did not evaluate the patient properly. The patient required more monitoring
because he could have been in danger when the naloxone wore off. The patient also needed
diagnostic testing to determine which drug he had taken and whether he had any metabolic
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 54
Office of the Inspector General State of California
imbalances from the overdose. Unfortunately, the provider failed to examine the patient, did
not arrange the needed monitoring or testing, and inappropriately released the patient back
to regular housing. The patient overdosed again two days later. We also discussed this case
in the Emergency Services indicator.
• In case 13, the provider failed to examine a patient with severely elevated blood pressure
and symptoms suggestive of a hypertensive emergency. This error increased the patient’s
risk of stroke and other complications.
Review of Records
Providers also did not always review their patients’ medical records with sufficient depth or
detail. We found this frequent error in cases 3, 12, 18, and the following cases:
• In case 21, the patient had chronic eye problems after having multiple surgeries and
returning from an ophthalmology appointment. The provider did not review the patient’s
record and did not know the patient did not have a needed ophthalmology follow-up
appointment scheduled. The provider did not order the follow-up appointment, placing the
patient at risk for a lapse in care.
• In case 28, the patient returned to PVSP from the hospital with recommendations to see a
cardiologist in two weeks because he recently had a pacemaker implanted. The provider did
not sufficiently review the records and failed to order the cardiology follow-up appointment.
The cardiology appointment did not occur.
• In case 38, the nurse referred the patient for a two-week provider appointment for knee pain.
The provider failed to review the patient’s medical record, did not address the reason for the
appointment, and did not review the X-ray of the patient’s knee, which had been performed
for this issue.
Chronic Care
To reduce the risk for both acute and long-term complications of chronic health problems, such
as diabetes mellitus, hypertension, and hyperlipidemia, it is important that providers both
identify and appropriately manage these conditions. At PVSP, we found that providers usually
performed acceptably in these areas, but needed to exercise more diligence when patients refused
their appointments:
• In case 18, staff discharged the patient from the TTA after treating him for a chronic,
non-healing wound. When the patient refused his initial provider follow-up appointment, the
staff failed to provide the information needed for him to make an informed decision. After
this error, the provider failed to review the patient’s medical record, determine a safe
follow-up interval, or order a follow-up appointment. The patient’s care lapsed; the patient
received no further appointments during our review period.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 55
Office of the Inspector General State of California
Specialty Services
We reviewed 37 specialty services encounters at PVSP. Providers usually referred their patients
appropriately to specialists and saw their patients when they returned. However, providers did
not always review their patients’ medical records correctly:
• In case 12, the patient returned from an offsite specialty appointment during which the
specialist used a camera to examine the patient’s stomach and intestines, and to obtain a
biopsy. During the patient’s follow-up appointment, the provider neglected to review the
patient’s medical record and did not address the biopsy result. Fortunately, the biopsy did
not show any cancer.
Emergency Care
The institution’s providers performed poorly with emergency care and contributed to multiple
occurrences wherein staff placed patients at undue risk of harm. Refer to the Emergency Services
indicator for more details.
Specialized Medical Housing
We reviewed seven cases in which patients received care in the specialized housing unit.
Provider care was usually sufficient in this area.
Clinician Onsite Inspection
PVSP physician leaders reported that although recent staffing was sufficient to maintain access
to care, they needed to ask providers to minimize taking any time off from their work to avoid
appointment backlogs. According to PVSP leadership, it would be difficult to continue to sustain
this work pressure on the institution’s providers. Even more problematic was the possibility of
having two or three additional provider vacancies in the near future. The institution’s leadership
indicated that it would be difficult to recruit new providers to PVSP because of its remote
location. In addition, PVSP is located in an area endemic to valley fever, and new providers
might not be willing to expose themselves to this additional health risk.
Morale was high at the institution. Most providers enjoyed working at PVSP and reported feeling
supported by their leadership. Most providers enjoyed a four-day, ten-hour work week to balance
the long commute from their homes. The majority of providers expressed the opinion that the
health care system at PVSP worked well, but that improvements could be made in obtaining
pathology reports quicker. Providers also commented that emergency transports were
occasionally delayed because of insufficient custody support.
Case Review Conclusion
The institution’s providers gave inconsistent quality of care to their patients. In emergency
services, providers performed poorly and placed their patients at undue risk of harm.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 56
Office of the Inspector General State of California
Furthermore, providers frequently demonstrated poor decision-making skills and often did not
review their patients’ medical records satisfactorily. Compared to Cycle 4, we found that
providers’ emergency care, decision-making, and record review had regressed. We rated the
Quality of Provider Performance indicator inadequate.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 57
Office of the Inspector General State of California
RECEPTION CENTER ARRIVALS
This indicator focuses on the management of medical needs and
Case Review Rating:
continuity of care for patients arriving from outside the CDCR
Not Applicable
system. The OIG review includes evaluation of the ability of the
Compliance Score:
institution to provide and document initial health screenings, initial
Not Applicable
health assessments, continuity of medications, and completion of
Overall Rating:
required screening tests; address and provide significant
Not Applicable
accommodations for disabilities and health care appliance needs; and
identify health care conditions needing treatment and monitoring.
The patients reviewed for reception center cases are those received from non-CDCR facilities,
such as county jails.
PVSP does not have a reception center; therefore, this indicator does not apply.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 58
Office of the Inspector General State of California
SPECIALIZED MEDICAL HOUSING
This indicator addresses whether the institution follows appropriate
Case Review Rating:
policies and procedures when admitting patients to onsite inpatient Adequate
facilities, including completion of timely nursing and provider Compliance Score:
assessments. The case review assesses all aspects of medical care Proficient
(92.5%)
related to these housing units, including quality of provider and
nursing care. PVSP’s only specialized medical housing unit is a Overall Rating:
correctional treatment center (CTC). Adequate
For this indicator, the case review and compliance review processes yielded different results,
with the case reviewers assigning an adequate rating and the compliance testing resulting in a
proficient score. Because the compliance tests in this indicator do not sufficiently reflect the
quality of patient care, we relied on the case review rating for the overall rating of this indicator.
Our case reviewers found sporadic problems with nursing care, as well as occasional medication
discontinuity. We determined that the overall rating for this indicator was adequate.
Case Review Results
We reviewed eight patients who received care in the CTC. The patients were admitted for
various reasons, including wound care, post-operative care, and intravenous antibiotic therapy.
We reviewed 81 events, which included 30 provider and 30 nursing encounters. We identified
five deficiencies, only one of which was significant. Case reviewers rated this indicator
adequate.
Provider Performance
The CTC cases we reviewed were of patients who had straightforward medical problems, such as
a simple wound infection or simply needed close observation. Providers performed appropriately
and delivered satisfactory care. Providers regularly evaluated and managed their CTC patients
correctly.
Nursing Performance
The institution’s nurses provided efficient and well-coordinated nursing care. Nurses conducted
daily patient assessments, reported the status of daily living activities, provided wound care,
re-assessed patients after the administration of pain medication, implemented provider orders,
and documented patient refusals. We found two minor nursing deficiencies:
• In case 4, the nurse did not record the appearance of the patient’s scalp laceration or the
removal of the staples.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 59
Office of the Inspector General State of California
• In case 19, the patient was assigned to an isolation room. The nurse failed to make a care
plan that addressed goals to prevent infections of the patient’s intravenous site and wound,
as well as the psychosocial environmental challenges for the patient.
Medication Management
The institution’s nurses usually administered medications appropriately in the CTC. We found
only one deficiency in this area:
• In case 5, CTC nurses missed administering a dose of antibiotic medication for one day.
Lapses in antibiotic administration can place patients at risk for worsening infections and
other complications.
Clinician Onsite Inspection
At the time of our clinicians’ onsite visit to PVSP, the CTC had been closed since March 2018
due to needed repairs for a leaky roof. It was unknown when the CTC would reopen. PVSP had
sent its CTC patients to other CDCR institutions’ CTCs. Because PVSP’s CTC was closed, the
institution was able to place its CTC nursing staff in other units, such as the TTA, R&R, and the
nurse sick-call lines for cross-training. The CTC nurses we interviewed appreciated the
additional training, expressed positive morale, and felt supported by their supervisors.
Case Review Conclusion
In general, patients at PVSP were medically straightforward and did not have complex needs.
PVSP staff members were able to meet their CTC patients’ needs without difficulty. The
occasional lapses in care we found did not increase the risk of harm to patients. Our case
reviewers rated this indicator adequate.
Compliance Testing Results
The institution received a proficient compliance score of 92.5 percent in this indicator. Four tests
earned scores in the proficient range:
• For all ten patients sampled, nursing staff timely completed an initial health assessment the
same day they admitted the patient to the CTC (MIT 13.001).
• Providers evaluated nine out of the ten patients sampled within 24 hours of admission to the
CTC (90.0 percent). The provider evaluated one patient 104 minutes late (MIT 13.002).
• We observed the working order of sampled call buttons in CTC patient rooms and found all
working properly. According to staff members we interviewed, custody officers and
clinicians were able to expeditiously access patients’ locked rooms when emergent events
occurred (MIT 13.101).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 60
Office of the Inspector General State of California
One test was adequate:
• PVSP’s providers timely completed their Subjective, Objective, Assessment, Plan, and
Education (SOAPE) notes at required three-day intervals for eight of ten sampled patients
(80.0 percent). Providers completed their SOAPE notes one day late for two patients. Also,
for one of these two patients, the provider did not document a complete SOAPE note
(MIT 13.003).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 61
Office of the Inspector General State of California
SPECIALTY SERVICES
This indicator focuses on specialist care from the time a physician
Case Review Rating:
completes a request for services or a physician’s order for specialist Adequate
care to the time of receipt of related recommendations from Compliance Score:
specialists. This indicator also evaluates the providers’ timely review Adequate
(80.6%)
of specialist records and documentation reflecting the patients’ care
plans, including the course of care when specialist recommendations Overall Rating:
were not ordered, and whether the results of specialists’ reports are Adequate
communicated to the patients. For specialty services denied by the
institution, the OIG determines whether the denials are timely and appropriate, and whether the
provider updates the patient on the plan of care.
Case Review Results
We reviewed 73 events related to Specialty Services, which included 46 specialty consultations
and procedures. We found 17 deficiencies in this category, 3 of which were significant. The case
review rating for this indicator was adequate.
Access to Specialty Services
PVSP usually had no problem with providing timely access to specialty services. We found only
one scheduling deficiency:
• In case 21, the patient had a complex retinal eye disease. The consulting eye doctor
requested a two-month follow-up appointment for the patient, however, the appointment did
not occur.
Health Information Management
PVSP staff had room for improvement in retrieving specialty reports. We found specialty reports
that were retrieved late or not at all. While these deficiencies did not result in harm, they did
increase the risk of lapses in care. These deficiencies occurred in cases 8, 17, 29, and the
following cases:
• In case 15, the infectious disease report was not retrieved in a timely manner. The specialist
recommended decreasing the dose of antibiotic medication. The specialty recommendations
did not reach the primary provider until nine days after the patient’s appointment.
• In case 41, the magnetic resonance imaging (MRI) report and infectious disease
recommendations were unavailable for provider review when the patient saw his regular
provider six days after the procedure and consultation.
In addition, providers failed to sign specialty reports in cases 8 and 20.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 62
Office of the Inspector General State of California
Nursing Performance
Nurses performed well in assessing patients, reviewing specialty reports, and documenting
encounters. However, when specialty reports were not immediately available, nurses failed to
obtain the report or inform the specialty clinic staff to follow up on the missing reports. PVSP’s
management confirmed it was the responsibility of the nurses to retrieve specialists’
recommendations and transmit them to the primary provider when patients returned from offsite
specialty appointments. The following case illustrates a deficiency in this area:
• In case 15, as noted previously, the telemedicine specialist recommended reducing the
dosage of an important antibiotic for the patient. However, the telemedicine nurse who was
present during the visit did not transmit the recommendation to the provider. This error
contributed to the delay in decreasing the dosage of the patient’s medication.
We also found two significant nursing deficiencies that also contributed to delays in medical care
in the following cases:
• In case 20, the patient was scheduled for an urgent eye surgery. The surgery was delayed for
three days because the nurse failed to ensure the patient did not eat breakfast the day of the
surgery. The patient could not have anesthesia with a full stomach, so the surgery had to be
postponed.
• In case 39, the patient was scheduled for an important cardiac stress test to evaluate the
patient’s risk of coronary artery disease. When the patient refused the test, the nurse did not
refer the patient back to the primary provider to determine if or when the test should be
rescheduled.
Provider Performance
The institution’s providers usually referred their patients to appropriate specialists within safe
time frames. When specialty reports were available, the providers usually reviewed the reports
timely and acted on them correctly.
Clinician Onsite Inspection
We noted the specialty services process at PVSP was fragmented and uncoordinated. No one was
responsible for coordinating efforts to ensure adequate tracking of the operation from start to
finish. When we inquired about the patient who refused the cardiology test (case 39), PVSP’s
health care staff claimed that a follow-up appointment was not scheduled because the provider
did not request one. However, we found no evidence that health care staff notified the provider
of the patient’s refusal or that the provider was aware of the refusal. The institution should
ensure that providers review the refusals of these important medical appointments. In addition,
we found many incomplete retrievals of consultation reports because the institution’s staff did
not sufficiently track specialty reports.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 63
Office of the Inspector General State of California
Case Review Conclusion
Providers referred patients to specialists appropriately. The institution scheduled and completed
most specialty services timely. When patients returned from specialty appointments, nurses
usually assessed these patients correctly. However, we found multiple problems with the
institution’s inability to retrieve specialty reports timely and consistently. When specialty
recommendations were unavailable, nurses often failed to retrieve those recommendations and
transmit them to the primary provider. At PVSP, no one was assigned to coordinate or oversee
the entire specialty services process, which contributed to some of these problems. Compared to
Cycle 4, PVSP’s performance in this area had significantly regressed. Nonetheless, most patients
still received the specialty care they needed. The deficiencies we found did not place the patients
at serious risk of harm. We rated the Specialty Services indicator adequate.
Compliance Testing Results
The institution received an adequate compliance score of 80.6 percent in this indicator, with the
following three tests scoring in the proficient range:
• The institution provided high-priority specialty services appointments within 14 days of the
provider’s order to 14 of 15 patients sampled (93.3 percent). The institution provided one
patient’s specialty services appointment three days late (MIT 14.001).
• PVSP provided routine specialty services appointments to 14 of 15 patients sampled within
90 days of the provider’s order (93.3 percent). PVSP provided one patient’s routine specialty
services appointment 27 days late (MIT 14.003).
• PVSP’s health care management timely denied providers’ specialty services requests for all
20 patients sampled (MIT 14.006).
Two tests scored in the adequate range:
• Providers timely received and reviewed the high-priority specialists’ reports for 11 of the
14 applicable patients (78.6 percent). One patient’s report was received 21 days late.
Another patient’s report was received and reviewed one day late. Finally, the institution did
not scan one remaining patient’s high-priority specialty report into the patient’s electronic
medical record (MIT 14.002).
• When an institution approves or schedules a patient for specialty services appointments and
then transfers the patient to another institution, policy requires that the receiving institution
ensure a patient’s appointment occurs timely. At PVSP, 15 of the 20 patients who
transferred from another institution (75.0 percent) received their specialty services
appointments within the required time frame. The institution provided previously approved
services to the remaining five patients from 7 to 72 days late (MIT 14.005).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 64
Office of the Inspector General State of California
Two tests earned inadequate scores:
• Providers timely received and reviewed specialists’ reports following routine specialty
service appointments for 7 of the 14 sampled patients (50.0 percent). For three patients, the
provider reviewed their reports five to nine days late. For another two patients, the
institution did not scan the specialty reports into the patients’ electronic medical records. For
another patient, the institution received the report 33 days late. For one final patient, the
provider did not indicate review by dating and initialing the report (MIT 14.004).
• Among 19 applicable patients who had a specialty service denied by PVSP’s health care
management, 14 of them (73.7 percent) received timely notification of the denied service.
For three patients, the denials were communicated one to four days late. For the two
remaining patients, the providers did not communicate their denials at all. (MIT 14.007).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 65
Office of the Inspector General State of California
ADMINISTRATIVE OPERATIONS (SECONDARY)
This indicator focuses on the institution’s administrative health care
Case Review Rating:
oversight functions. The OIG evaluates whether the institution Not Applicable
promptly processes patient medical appeals and addresses all Compliance Score:
appealed issues. Inspectors also verify that the institution follows Adequate
(81.3%)
reporting requirements for adverse/sentinel events and patient deaths.
The OIG verifies that the Emergency Medical Response Review Overall Rating:
Committee (EMRRC) performs required reviews and that staff Adequate
perform required emergency response drills. Inspectors also assess
whether the Quality Management Committee (QMC) meets regularly and adequately addresses
program performance. For those institutions with licensed facilities, inspectors also verify that
required committee meetings are held. In addition, the OIG examines whether the institution
adequately manages its health care staffing resources by evaluating whether job performance
reviews are completed as required; specified staff possess current, valid credentials and
professional licenses or certifications; nursing staff receive new employee orientation training
and annual competency testing; and clinical and custody staff have current emergency medical
response certifications. The Administrative Operations indicator is a secondary indicator;
therefore, it was not relied on for the institution’s overall score.
Compliance Testing Results
The institution received an adequate score of 81.3 percent in this indicator, with several tests
earning proficient scores:
• The institution timely processed patient medical appeals in 11 of 12 months reviewed
(91.7 percent). For one month, 25 percent of medical appeals were overdue (MIT 15.001).
• PVSP’s Quality Management Committee (QMC) met monthly, evaluated program
performance, and acted when management identified areas for improvement opportunities
(MIT 15.003).
• PVSP took adequate steps to ensure the accuracy of its Dashboard data reporting
(MIT 15.004).
• The OIG inspected incident package documentation for 12 emergency medical responses
reviewed by PVSP’s EMRRC during the prior six-month period; all 12 sampled packages
complied with policy (MIT 15.005).
• Based on a sample of ten second-level medical appeals, the institution’s responses addressed
all the patients’ appealed issues (MIT 15.102).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 66
Office of the Inspector General State of California
• All ten nurses sampled were current with their clinical competency validations
(MIT 15.105).
• The OIG reviewed performance evaluation packets for PVSP’s seven providers; PVSP met
all performance review requirements for its providers (MIT 15.106).
• All providers at the institution were current with their professional licenses. Similarly, all
nursing staff and the PIC were current with their professional licenses and certification
requirements (MIT 15.107, 15.109).
• All active-duty providers and nurses were current with their emergency response
certifications (MIT 15.108).
• All pharmacy staff and providers who prescribed controlled substances had current Drug
Enforcement Agency registrations (MIT 15.110).
One test earned an adequate score:
• PVSP’s Local Governing Body (LGB) met quarterly and exercised responsibility for the
quality management of patient health care in three of the four prior quarters (75.0 percent).
In the second quarter, PVSP did not timely approve the LGB meeting minutes dated
June 1, 2017 (MIT 15.006).
Four tests earned scores in the inadequate range:
• The institution did not meet the emergency response drill requirements for the most recent
quarter for one of its three watches, resulting in a score of 66.7 percent. The institution’s
first-watch drill package did not contain a Crime/Incident Report (CDCR Form 837) as
required by CCHCS policy (MIT 15.101).
• PVSP had three patient deaths occur during our sample test period. Medical staff reviewed
and timely submitted the initial Inmate Death Report (CDCR Form 7229A or 7229B) to
CCHCS’ Death Review Unit for two patient deaths, resulting in a score of 66.7 percent. For
one patient’s death, the institution failed to provide sufficient evidence that the CDCR Form
7229B was submitted timely (MIT 15.103).
• We inspected records from September 2017 for five nurses to determine if their nursing
supervisors properly completed monthly performance reviews. We identified the following
deficiencies: the supervisor did not discuss the review results with the subordinate nurse for
four nurses, and the supervisor’s review did not summarize aspects that were well done or
needing improvement for all five nurses. As a result, the institution scored zero for this test
(MIT 15.104).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 67
Office of the Inspector General State of California
• Of the 12 nurses PVSP hired within the last year, 11 received a timely new employee
orientation training. One nurse received this orientation 52 days late. As a result, the
institution scored zero for this test (MIT 15.111).
Non-Scored Results
• We gathered non-scored data regarding the CCHCS Death Review Committee (DRC)
completing its death review reports. Three unexpected (Level 1) deaths occurred during our
review period. CCHCS policy requires the DRC to complete its death review summary
report within 60 calendar days from the date of death for Level 1 deaths and submit these
reports to the institution’s CEO within seven calendar days thereafter. While one death
review report was completed timely, the DRC completed two other reports 19 and 46 days
late and submitted them to PVSP’s CEO 29 and 30 days late thereafter. For the third death,
CCHCS completed the review timely, but was 11 days late sending the report to the CEO
(MIT 15.998).
• The OIG discusses the institution’s health care staffing resources in the About the Institution
section of this report (MIT 15.999).
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 68
Office of the Inspector General State of California
R
ECOMMENDATIONS
The OIG recommends the following:
• The CEO should correct the review process of the EMRRC; the EMRRC failed to identify
problems with the institution’s emergency response and care provided by providers and
nurses in the TTA. PVSP needs a properly functioning EMRRC to identify and correct the
institution’s various lapses in emergency care.
• The CEO should address the numerous problems related to medications at PVSP by first
improving the pharmacy’s staffing levels. The PIC and the CNE should then implement
quality improvement measures to address the numerous problems with medication
management we found during this inspection.
• The CNE and the PIC should correct and then monitor the medication transfer process to
ensure medication continuity for patients transferring into and out of PVSP or returning
from an outside hospital. During our inspection, we found serious problems with medication
continuity in all transfer processes.
• The CNE should provide training to, and monitor, nurses in the R&R area and the TTA, as
these nurses are the primary staff responsible for coordinating and ensuring the continuity of
care for patients in these areas. During our inspection, nurses in R&R and the TTA did not
fulfill their responsibilities sufficiently.
• The CEO should revamp the specialty services processes to ensure PVSP staff coordinate
their efforts to deliver appropriate specialty care. During our inspection, we found a lack of
coordination, resulting in poor tracking of specialty appointments and sporadic performance
with retrieving specialty reports at PVSP. The CEO and the CNE should also develop and
implement a process that will ensure the institution’s staff refer patients who refuse specialty
services back to the primary provider for further evaluation.
• The CME should refine the current methods used to evaluate provider performance since we
found problems with provider performance in the emergency setting and issues with
superficial reviews of medical records.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 69
Office of the Inspector General State of California
P -B M
OPULATION ASED ETRICS
The compliance testing and the case reviews give an accurate assessment of how the institution’s
health care systems are functioning with regard to the patients with the highest risk and
utilization. This information is vital to assess the capacity of the institution to provide
sustainable, adequate care. However, one significant limitation of the case review methodology
is that it does not give a clear assessment of how the institution performs for the entire
population. For better insight into this performance, the OIG has turned to population-based
metrics. For comparative purposes, the OIG has selected several Healthcare Effectiveness Data
and Information Set (HEDIS) measures for disease management to gauge the institution’s
effectiveness in outpatient health care, especially chronic disease management.
The Healthcare Effectiveness Data and Information Set is a set of standardized performance
measures developed by the National Committee for Quality Assurance with input from over
300 organizations representing every sector of the nation’s health care industry. It is used by over
90 percent of the nation’s health plans as well as many leading employers and regulators. HEDIS
was designed to ensure that the public (including employers, the Centers for Medicare and
Medicaid Services, and researchers) has the information it needs to accurately compare the
performance of health care plans. Healthcare Effectiveness Data and Information Set data is
often used to produce health plan report cards, analyze quality improvement activities, and create
performance benchmarks.
Methodology
For population-based metrics, we used a subset of HEDIS measures applicable to the CDCR
patient population. Selection of the measures was based on the availability, reliability, and
feasibility of the data required for performing the measurement. We collected data utilizing
various information sources, including the electronic medical record, the Master Registry
(maintained by CCHCS), as well as a random sample of patient records analyzed and abstracted
by trained personnel. We did not independently validate the data obtained from the CCHCS
Master Registry and Diabetic Registry and we presume it to be accurate. For some measures, we
used the entire population rather than statistically random samples. While the OIG is not a
certified HEDIS compliance auditor, we use similar methods to ensure that measures are
comparable to those published by other organizations.
Comparison of Population-Based Metrics
For Pleasant Valley State Prison, nine HEDIS measures were selected and are listed in the
following PVSP Results Compared to State and National HEDIS Scores table. Multiple health
plans publish their HEDIS performance measures at the state and national levels. The OIG has
provided selected results for several health plans in both categories for comparative purposes.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 70
Office of the Inspector General State of California
Results of Population-Based Metric Comparison
Comprehensive Diabetes Care
For chronic care management, the OIG chose measures related to the management of diabetes.
Diabetes is the most complex common chronic disease requiring a high level of intervention on
the part of the health care system in order to produce optimal results. PVSP performed well with
its management of diabetes.
When compared statewide, PVSP outperformed or matched Medi-Cal in all five diabetic
measures. PVSP also outperformed Kaiser in four of the five diabetic measures. The institution
scored lower than Kaiser with regard to diabetic eye exams. When compared nationally, PVSP
outperformed Medicaid and commercial plans in all five diabetic measures. The institution
scored lower than Medicare and the VA regarding diabetic eye exams.
Immunizations
Comparative data for immunizations was only fully available for the VA and partially available
for Kaiser, commercial plans, Medicaid, and Medicare. With respect to administering influenza
vaccinations to younger adults, PVSP outperformed Medicaid and commercial plans. The
institution scored lower than Kaiser and the VA. No comparative data was presented regarding
vaccinations for older adults, as PVSP’s population of patients 65 years of age or older was zero
at the time of inspection.
Cancer Screening
With respect to colorectal cancer screening, PVSP matched Kaiser North and outperformed
commercial plans and Medicare. The institution scored lower than Kaiser South and the VA.
Summary
PVSP performed well with regard to population-based metrics in comparison to the other health
care plans reviewed. The institution may improve its scores with immunizations by reducing
patient refusals through patient education.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 71
Office of the Inspector General State of California
PVSP Results Compared to State and National HEDIS Scores
California National
HEDIS HEDIS
PVSP HEDIS
HEDIS Kaiser Kaiser HEDIS HEDIS VA
Clinical Measures Com-
Medi-Cal (No. (So. Medicaid Medicare Average
Cycle 5 mercial
20172 CA) CA) 20174 20174 20165
Results1 20174
20163 20163
Comprehensive Diabetes Care
HbA1c Testing (Monitoring)6 100% 87% 94% 94% 87% 91% 94% 99%
Poor HbA1c Control (>9.0%)6, 7 13% 38% 20% 23% 43% 33% 26% 18%
HbA1c Control (<8.0%)6 81% 52% 70% 63% 47% 56% 63% -
Blood Pressure Control
88% 63% 83% 83% 60% 62% 64% 76%
(<140/90)6
Eye Exams6 57% 57% 68% 81% 55% 54% 70% 89%
Immunizations
Influenza Shots - Adults (18–64) 49% - 56% 57% 39% 48% - 52%
Influenza Shots - Adults (65+)8 N/A - - - - - 71% 72%
Immunizations: Pneumococcal8 N/A - - - - - 74% 93%
Cancer Screening
Colorectal Cancer Screening 79% - 79% 82% - 62% 67% 82%
1. Unless otherwise stated, data was collected in November 2017 by reviewing medical records from a
sample of PVSP’s population of applicable patients. These random statistical sample sizes were based on a
95 percent confidence level with a 15 percent maximum margin of error.
2. HEDIS Medi-Cal data was obtained from the California Department of Health Care Services Medi-Cal
Managed Care External Quality Review Technical Report (July 1, 2016 – June 30, 2017).
3. Data was obtained from Kaiser Permanente November 2016 reports for the Northern and Southern
California regions.
4. National HEDIS data for Medicaid, commercial plans, and Medicare was obtained from the 2016 State of
Health Care Quality Report, available on the NCQA website: www.ncqa.org. The results for commercial
plans were based on data received from various health maintenance organizations.
5. The Department of Veterans Affairs (VA) data was obtained from the VA’s website, www.va.gov. For
the Immunizations: Pneumococcal measure only, the data was obtained from the VHA Facility Quality and
Safety Report - Fiscal Year 2012 Data.
6. For this indicator, the entire applicable PVSP population was tested.
7. For this measure only, a lower score is better. For Kaiser, the OIG derived the Poor HbA1c Control
indicator using the reported data for the <9.0% HbA1c control indicator.
8. The population did not contain any patients 65 years of age or older; therefore, this sample was omitted
from the comparative analysis.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 72
Office of the Inspector General State of California
A A — C T R
PPENDIX OMPLIANCE EST ESULTS
Pleasant Valley State Prison
Range of Summary Scores: 53.9% – 92.5%
Indicator Compliance Score (Yes %)
1 – Access to Care 87.4%
2 – Diagnostic Services 56.9%
3 – Emergency Services Not Applicable
4 – Health Information Management (Medical Records) 85.3%
5 – Health Care Environment 53.9%
6 – Inter- and Intra-System Transfers 83.8%
7 – Pharmacy and Medication Management 63.1%
8 – Prenatal and Post-Delivery Services Not Applicable
9 – Preventive Services 88.2%
10 – Quality of Nursing Performance Not Applicable
11 – Quality of Provider Performance Not Applicable
12 – Reception Center Arrivals Not Applicable
13 – Specialized Medical Housing (OHU, CTC, SNF, Hospice) 92.5%
14 – Specialty Services 80.6%
15 – Administrative Operations 81.3%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 73
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
1 – Access to Care
Number Yes No No Yes % N/A
Chronic care follow-up appointments: Was the patient’s most
recent chronic care visit within the health care guideline’s
1.001 19 6 25 76.0% 0
maximum allowable interval or within the ordered time frame,
whichever is shorter?
For endorsed patients received from another CDCR institution: If
1.002 the nurse referred the patient to a provider during the initial health 17 8 25 68.0% 0
screening, was the patient seen within the required time frame?
Clinical appointments: Did a registered nurse review the patient’s
1.003 29 1 30 96.7% 0
request for service the same day it was received?
Clinical appointments: Did the registered nurse complete a
1.004 face-to-face visit within one business day after the CDCR Form 27 2 29 93.1% 1
7362 was reviewed?
Clinical appointments: If the registered nurse determined a
referral to a primary care provider was necessary, was the patient
1.005 10 2 12 83.3% 18
seen within the maximum allowable time or the ordered time
frame, whichever is the shorter?
Sick call follow-up appointments: If the primary care provider
1.006 ordered a follow-up sick call appointment, did it take place within 8 0 8 100.0% 22
the time frame specified?
Upon the patient’s discharge from the community hospital: Did
1.007 the patient receive a follow-up appointment within the required 21 1 22 95.5% 0
time frame?
Specialty service follow-up appointments: Do specialty service
1.008 primary care physician follow-up visits occur within required time 17 6 23 73.9% 7
frames?
Clinical appointments: Do patients have a standardized process to
1.101 6 0 6 100.0% 0
obtain and submit health care services request forms?
Overall percentage: 87.4%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 74
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
2 – Diagnostic Services
Number Yes No No Yes % N/A
Radiology: Was the radiology service provided within the time
2.001 10 0 10 100.0% 0
frame specified in the provider’s order?
Radiology: Did the primary care provider review and initial the
2.002 2 8 10 20.0% 0
diagnostic report within specified time frames?
Radiology: Did the primary care provider communicate the results
2.003 5 5 10 50.0% 0
of the diagnostic study to the patient within specified time frames?
Laboratory: Was the laboratory service provided within the time
2.004 9 1 10 90.0% 0
frame specified in the provider’s order?
Laboratory: Did the primary care provider review and initial the
2.005 8 2 10 80.0% 0
diagnostic report within specified time frames?
Laboratory: Did the primary care provider communicate the
2.006 results of the diagnostic study to the patient within specified time 0 10 10 0.0% 0
frames?
Pathology: Did the institution receive the final diagnostic report
2.007 6 4 10 60.0% 0
within the required time frames?
Pathology: Did the primary care provider review and initial the
2.008 7 1 8 87.5% 2
diagnostic report within specified time frames?
Pathology: Did the primary care provider communicate the results
2.009 2 6 8 25.0% 2
of the diagnostic study to the patient within specified time frames?
Overall percentage: 56.9%
3 – Emergency Services
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 75
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
4 – Health Information Management
Number Yes No No Yes % N/A
Are non-dictated healthcare documents (provider progress notes)
4.001 8 0 8 100.0% 0
scanned within 3 calendar days of the patient encounter date?
Are dictated/transcribed documents scanned into the patient’s
4.002 electronic health record within five calendar days of the encounter Not Applicable
date?
Are High-Priority specialty notes (either a Form 7243 or other
4.003 scanned consulting report) scanned within the required time 14 6 20 70.0% 0
frame?
Are community hospital discharge documents scanned into the
4.004 patient’s electronic health record within three calendar days of 20 0 20 100.0% 0
hospital discharge?
Are medication administration records (MARs) scanned into the
4.005 Not Applicable
patient’s electronic health record within the required time frames?
During the inspection, were medical records properly scanned,
4.006 19 5 24 79.2% 0
labeled, and included in the correct patients’ files?
For patients discharged from a community hospital: Did the
preliminary hospital discharge report include key elements and
4.007 17 5 22 77.3% 0
did a primary care provider review the report within three
calendar days of discharge?
Overall percentage: 85.3%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 76
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
5 – Health Care Environment
Number Yes No No Yes % N/A
Are clinical health care areas appropriately disinfected, cleaned,
5.101 10 0 10 100.0% 0
and sanitary?
Do clinical health care areas ensure that reusable invasive and
5.102 non-invasive medical equipment is properly sterilized or 6 4 10 60.0% 0
disinfected as warranted?
Do clinical health care areas contain operable sinks and sufficient
5.103 8 2 10 80.0% 0
quantities of hygiene supplies?
Does clinical health care staff adhere to universal hand hygiene
5.104 6 4 10 60.0% 0
precautions?
Do clinical health care areas control exposure to blood-borne
5.105 4 6 10 40.0% 0
pathogens and contaminated waste?
Warehouse, Conex and other non-clinic storage areas: Does the
5.106 medical supply management process adequately support the needs 0 1 1 0.0% 0
of the medical health care program?
Does each clinic follow adequate protocols for managing and
5.107 3 7 10 30.0% 0
storing bulk medical supplies?
Do clinic common areas and exam rooms have essential core
5.108 2 8 10 20.0% 0
medical equipment and supplies?
Do clinic common areas have an adequate environment conducive
5.109 7 2 9 77.8% 1
to providing medical services?
Do clinic exam rooms have an adequate environment conducive
5.110 5 5 10 50.0% 0
to providing medical services?
Emergency response bags: Are TTA and clinic emergency
5.111 medical response bags inspected daily and inventoried monthly, 6 2 8 75.0% 2
and do they contain essential items?
Overall percentage: 53.9%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 77
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
6 – Inter- and Intra-System Transfers
Number Yes No No Yes % N/A
For endorsed patients received from another CDCR institution or
COCF: Did nursing staff complete the initial health screening and
6.001 24 1 25 96.0% 0
answer all screening questions on the same day the patient arrived
at the institution?
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
disposition section of the health screening form; refer the patient
6.002 25 0 25 100.0% 0
to the TTA, if TB signs and symptoms were present; and sign and
date the form on the same day staff completed the health
screening?
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon
6.003 8 2 10 80.0% 15
arrival, were medications administered or delivered without
interruption?
For patients transferred out of the facility: Were scheduled
6.004 specialty service appointments identified on the patient’s health 6 8 14 42.9% 0
care transfer information form?
For patients transferred out of the facility: Do medication transfer
6.101 packages include required medications along with the 2 0 2 100.0% 8
corresponding transfer packet required documents?
Overall percentage: 83.8%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 78
Office of the Inspector General State of California
Scored Answers
7 – Pharmacy and Medication Yes
Reference +
Management
Number Yes No No Yes % N/A
Did the patient receive all chronic care medications within the
7.001 required time frames or did the institution follow departmental 10 5 15 66.7% 10
policy for refusals or no-shows?
Did health care staff administer, make available, or deliver new
7.002 order prescription medications to the patient within the required 20 5 25 80.0% 0
time frames?
Upon the patient’s discharge from a community hospital: Were all
7.003 ordered medications administered, made available, or delivered to 15 7 22 68.2% 0
the patient within required time frames?
For patients received from a county jail: Were all medications
ordered by the institution’s reception center provider
7.004 Not Applicable
administered, made available, or delivered to the patient within
the required time frames?
Upon the patient’s transfer from one housing unit to another:
7.005 23 2 25 92.0% 0
Were medications continued without interruption?
For patients en route who lay over at the institution: If the
7.006 temporarily housed patient had an existing medication order, were Not Applicable
medications administered or delivered without interruption?
All clinical and medication line storage areas for narcotic
7.101 medications: Does the Institution employ strong medication 4 3 7 57.1% 3
security over narcotic medications assigned to its clinical areas?
All clinical and medication line storage areas for non-narcotic
medications: Does the Institution properly store non-narcotic
7.102 2 6 8 25.0% 2
medications that do not require refrigeration in assigned clinical
areas?
All clinical and medication line storage areas for non-narcotic
7.103 medications: Does the institution properly store non-narcotic 4 5 9 44.4% 1
medications that require refrigeration in assigned clinical areas?
Medication preparation and administration areas: Do nursing staff
employ and follow hand hygiene contamination control protocols
7.104 5 1 6 83.3% 4
during medication preparation and medication administration
processes?
Medication preparation and administration areas: Does the
7.105 institution employ appropriate administrative controls and 6 0 6 100.0% 4
protocols when preparing medications for patients?
Medication preparation and administration areas: Does the
7.106 Institution employ appropriate administrative controls and 3 3 6 50.0% 4
protocols when distributing medications to patients?
Pharmacy: Does the institution employ and follow general
7.107 security, organization, and cleanliness management protocols in 1 0 1 100.0% 0
its main and satellite pharmacies?
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 79
Office of the Inspector General State of California
Scored Answers
7 – Pharmacy and Medication Yes
Reference +
Management
Number Yes No No Yes % N/A
Pharmacy: Does the institution’s pharmacy properly store
7.108 0 1 1 0.0% 0
non-refrigerated medications?
Pharmacy: Does the institution’s pharmacy properly store
7.109 0 1 1 0.0% 0
refrigerated or frozen medications?
Pharmacy: Does the institution’s pharmacy properly account for
7.110 1 0 1 100.0% 0
narcotic medications?
Does the institution follow key medication error reporting
7.111 20 5 25 80.0% 0
protocols?
Overall percentage: 62.8%
8 – Prenatal and Post-Delivery Services
The institution had no female patients, so this indicator was not applicable.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 80
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
9 – Preventive Services
Number Yes No No Yes % N/A
Patients prescribed TB medication: Did the institution administer
9.001 8 4 12 66.7% 0
the medication to the patient as prescribed?
Patients prescribed TB medication: Did the institution monitor the
9.002 patient monthly for the most recent three months he or she was on 12 0 12 100.0% 0
the medication?
Annual TB Screening: Was the patient screened for TB within the
9.003 23 7 30 76.7% 0
last year?
Were all patients offered an influenza vaccination for the most
9.004 25 0 25 100.0% 0
recent influenza season?
All patients from the age of 50 - 75: Was the patient offered
9.005 24 1 25 96.0% 0
colorectal cancer screening?
Female patients from the age of 50 through the age of 74: Was the
9.006 Not Applicable
patient offered a mammogram in compliance with policy?
Female patients from the age of 21 through the age of 65: Was
9.007 Not Applicable
patient offered a pap smear in compliance with policy?
Are required immunizations being offered for chronic care
9.008 14 1 15 93.3% 10
patients?
Are patients at the highest risk of coccidioidomycosis (valley
9.009 17 3 20 85.0% 0
fever) infection transferred out of the facility in a timely manner?
Overall percentage: 88.2%
10 – Quality of Nursing Performance
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
11 – Quality of Provider Performance
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 81
Office of the Inspector General State of California
12 – Reception Center Arrivals
The institution had no reception center, so this indicator was not applicable.
Scored Answers
Yes
Reference +
13 – Specialized Medical Housing
Number Yes No No Yes % N/A
For OHU, CTC, and SNF: Did the registered nurse complete an
13.001 initial assessment of the patient on the day of admission, or within 10 0 10 100.0% 0
eight hours of admission to CMF’s Hospice?
For CTC and SNF only: Was a written history and physical
13.002 9 1 10 90.0% 0
examination completed within the required time frame?
For OHU, CTC, SNF, and Hospice: Did the primary care provider
complete the Subjective, Objective, Assessment, Plan, and
13.003 8 2 10 80.0% 0
Education (SOAPE) notes on the patient at the minimum intervals
required for the type of facility where the patient was treated?
For OHU and CTC only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
13.101 1 0 1 100.0% 0
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells?
Overall percentage: 92.5%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 82
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
14 – Specialty Services
Number Yes No No Yes % N/A
Did the patient receive the high priority specialty service within
14.001 14 calendar days of the primary care provider order or the 14 1 15 93.3% 0
Physician Request for Service?
Did the primary care provider review the high priority specialty
14.002 11 3 14 78.6% 1
service consultant report within the required time frame?
Did the patient receive the routine specialty service within 90
14.003 calendar days of the primary care provider order or Physician 14 1 15 93.3% 0
Request for Service?
Did the primary care provider review the routine specialty service
14.004 7 7 14 50.0% 1
consultant report within the required time frame?
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at
14.005 15 5 20 75.0% 0
the sending institution, was the appointment scheduled at the
receiving institution within the required time frames?
Did the institution deny the primary care provider request for
14.006 20 0 20 100.0% 0
specialty services within required time frames?
Following the denial of a request for specialty services, was the
14.007 14 5 19 73.7% 1
patient informed of the denial within the required time frame?
Overall percentage: 80.6%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 83
Office of the Inspector General State of California
Scored Answers
Reference Yes
15 – Administrative Operations +
Number Yes No No Yes % N/A
Did the institution promptly process inmate medical appeals
15.001 11 1 12 91.7% 0
during the most recent 12 months?
Does the institution follow adverse / sentinel event reporting
15.002 Not Applicable
requirements?
Did the institution Quality Management Committee (QMC) meet
at least monthly to evaluate program performance, and did the
15.003 6 0 6 100.0% 0
QMC take action when improvement opportunities were
identified?
Did the institution’s Quality Management Committee (QMC) or
15.004 other forum take steps to ensure the accuracy of its Dashboard 1 0 1 100.0% 0
data reporting?
Does the Emergency Medical Response Review Committee
15.005 perform timely incident package reviews that include the use of 12 0 12 100.0% 0
required review documents?
For institutions with licensed care facilities: Does the Local
Governing Body (LGB), or its equivalent, meet quarterly and
15.006 3 1 4 75.0% 0
exercise its overall responsibilities for the quality management of
patient health care?
Did the institution complete a medical emergency response drill
15.101 for each watch and include participation of health care and 2 1 3 66.7% 0
custody staff during the most recent full quarter?
Did the institution’s second level medical appeal response address
15.102 10 0 10 100.0% 0
all of the patient’s appealed issues?
Did the institution’s medical staff review and submit the initial
15.103 2 1 3 66.7% 0
inmate death report to the Death Review Unit in a timely manner?
Does the institution’s Supervising Registered Nurse conduct
15.104 0 5 5 0.0% 0
periodic reviews of nursing staff?
Are nursing staff who administer medications current on their
15.105 10 0 10 100.0% 0
clinical competency validation?
15.106 Are structured clinical performance appraisals completed timely? 7 0 7 100.0% 0
15.107 Do all providers maintain a current medical license? 9 0 9 100.0% 0
Are staff current with required medical emergency response
15.108 2 0 2 100.0% 1
certifications?
Are nursing staff and the Pharmacist-in-Charge current with their
professional licenses and certifications, and is the pharmacy
15.109 6 0 6 100.0% 1
licensed as a correctional pharmacy by the California State Board
of Pharmacy?
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 84
Office of the Inspector General State of California
Scored Answers
Yes
Reference
15 – Administrative Operations +
Number Yes No No Yes % N/A
Do the institution’s pharmacy and authorized providers who
15.110 prescribe controlled substances maintain current Drug 1 0 1 100.0% 0
Enforcement Agency (DEA) registrations?
15.111 Are nursing staff current with required new employee orientation? 0 1 1 0.0% 0
Overall percentage: 81.3%
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 85
Office of the Inspector General State of California
A B — C D
PPENDIX LINICAL ATA
Table B-1: PVSP Sample Sets
Sample Set Total
Death Review/Sentinel Events 3
Diabetes 3
Emergency Services – CPR 2
Emergency Services – Non-CPR 3
High Risk 3
Hospitalization 5
Intra-System Transfers In 3
Intra-System Transfers Out 3
RN Sick Call 18
Specialty Services 3
46
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 86
Office of the Inspector General State of California
Table B-2: PVSP Chronic Care Diagnoses
Diagnosis Total
Anemia 2
Arthritis/Degenerative Joint Disease 5
Asthma 7
COPD 3
Cardiovascular Disease 1
Chronic Pain 20
Cirrhosis/End-Stage Liver Disease 1
Coccidioidomycosis 8
Diabetes 4
Gastroesophageal Reflux Disease 10
Gastrointestinal Bleed 1
Hepatitis C 17
Hyperlipidemia 5
Hypertension 11
Mental Health 14
Rheumatological Disease 1
Seizure Disorder 5
Thyroid Disease 2
117
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 87
Office of the Inspector General State of California
Table B-3: PVSP Event – Program
Diagnosis Total
96
Diagnostic Services
38
Emergency Care
37
Hospitalization
11
Intra-System Transfers In
6
Intra-System Transfers Out
389
Outpatient Care
78
Specialized Medical Housing
70
Specialty Services
725
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 88
Office of the Inspector General State of California
Table B-4: PVSP Review Sample Summary
Total
MD Reviews Detailed 22
MD Reviews Focused 0
RN Reviews Detailed 15
RN Reviews Focused 25
Total Reviews 62
Total Unique Cases 46
Overlapping Reviews (MD & RN) 16
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 89
Office of the Inspector General State of California
A C — C S M
PPENDIX OMPLIANCE AMPLING ETHODOLOGY
Pleasant Valley State Prison
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Access to Care
MIT 1.001 Chronic Care Patients Master Registry • Chronic care conditions (at least one condition per
patient—any risk level)
(25) • Randomize
MIT 1.002 Nursing Referrals OIG Q: 6.001 • See Intra-system Transfers
(25)
MITs 1.003–006 Nursing Sick Call MedSATS • Clinic (each clinic tested)
(5 per clinic) • Appointment date (2–9 months)
(30) • Randomize
MIT 1.007 Returns from OIG Q: 4.007 • See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(22)
MIT 1.008 Specialty Services OIG Q: 14.001 & • See Specialty Services
Follow-up 14.003
(30)
MIT 1.101 Availability of Health OIG onsite • Randomly select one housing unit from each yard
Care Services review
Request Forms
(6)
Diagnostic Services
MITs 2.001–003 Radiology Radiology Logs • Appointment date (90 days–9 months)
• Randomize
(10) • Abnormal
MITs 2.004–006 Laboratory Quest • Appt. date (90 days–9 months)
• Order name (CBC or CMPs only)
• Randomize
(10) • Abnormal
MITs 2.007–009 Pathology InterQual • Appt. date (90 days–9 months)
• Service (pathology related)
(10) • Randomize
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 90
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Timely Scanning OIG Qs: 1.001, • Non-dictated documents
(8) 1.002, & 1.004 • 1st 10 IPs MIT 1.001, 1st 5 IPs MITs 1.002, 1.004
MIT 4.002 OIG Q: 1.001 • Dictated documents
(0) • First 20 IPs selected
MIT 4.003 OIG Qs: 14.002 • Specialty documents
(20) & 14.004 • First 10 IPs for each question
MIT 4.004 OIG Q: 4.007 • Community hospital discharge documents
(20) • First 20 IPs selected
MIT 4.005 OIG Q: 7.001 • MARs
(0) • First 20 IPs selected
MIT 4.006 Documents for • Any misfiled or mislabeled document identified
(5) any tested inmate during OIG compliance review (24 or more = No)
MIT 4.007 Returns From Inpatient claims • Date (2–8 months)
Community Hospital data • Most recent 6 months provided (within date range)
• Rx count
• Discharge date
• Randomize (each month individually)
• First 5 patients from each of the 6 months (if not 5
in a month, supplement from another, as needed)
(22)
Health Care Environment
MIT 5.101–105 Clinical Areas OIG inspector • Identify and inspect all onsite clinical areas.
MIT 5.107–111 (10) onsite review
Inter- and Intra-System Transfers
MIT 6.001–003 Intra-System SOMS • Arrival date (3–9 months)
Transfers • Arrived from (another CDCR facility)
• Rx count
• Randomize
(25)
MIT 6.004 Specialty Services MedSATS • Date of transfer (3–9 months)
Send-Outs • Randomize
(14)
MIT 6.101 Transfers Out OIG inspector • R&R IP transfers with medication
(10) onsite review
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 91
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care OIG Q: 1.001 See Access to Care
Medication • At least one condition per patient—any risk level
• Randomize
(25)
MIT 7.002 New Medication Master Registry • Rx count
Orders • Randomize
(25) • Ensure no duplication of IPs tested in MIT 7.001
MIT 7.003 Returns from OIG Q: 4.007 • See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(22)
MIT 7.004 RC Arrivals – OIG Q: 12.001 • See Reception Center Arrivals
Medication Orders
(N/A at this
institution)
MIT 7.005 Intra-Facility Moves MAPIP transfer • Date of transfer (2–8 months)
data • To location/from location (yard to yard and
to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
(25)
• Randomize
MIT 7.006 En Route SOMS • Date of transfer (2–8 months)
• Sending institution (another CDCR facility)
• Randomize
(0) • NA/DOT meds
MITs 7.101–103 Medication Storage OIG inspector • Identify and inspect clinical & med line areas that
Areas onsite review store medications
(varies by test)
MITs 7.104–106 Medication OIG inspector • Identify and inspect onsite clinical areas that
Preparation and onsite review prepare and administer medications
Administration Areas
(varies by test)
MITs 7.107–110 Pharmacy OIG inspector • Identify & inspect all onsite pharmacies
(1) onsite review
MIT 7.111 Medication Error Monthly • All monthly statistic reports with Level 4 or higher
Reporting medication error • Select a total of 5 months
(25) reports
MIT 7.999 Isolation Unit KOP Onsite active • KOP rescue inhalers & nitroglycerin medications
Medications medication for IPs housed in isolation units
(4) listing
Prenatal and Post-Delivery Services
MIT 8.001–007 Recent Deliveries OB Roster • Delivery date (2–12 months)
(N/A at this • Most recent deliveries (within date range)
institution)
Pregnant Arrivals OB Roster • Arrival date (2–12 months)
(N/A at this • Earliest arrivals (within date range)
institution)
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 92
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Preventive Services
MITs 9.001–002 TB Medications Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months or 12 weeks)
(12) • Randomize
MIT 9.003 TB Evaluation, SOMS • Arrival date (at least 1 year prior to inspection)
Annual Screening • Birth Month
(30) • Randomize
MIT 9.004 Influenza SOMS • Arrival date (at least 1 year prior to inspection)
Vaccinations • Randomize
(25) • Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer SOMS • Arrival date (at least 1 year prior to inspection)
Screening • Date of birth (51 or older)
(25) • Randomize
MIT 9.006 Mammogram SOMS • Arrival date (at least 2 yrs prior to inspection)
(N/A at this • Date of birth (age 52–74)
institution) • Randomize
MIT 9.007 Pap Smear SOMS • Arrival date (at least three yrs prior to inspection)
(N/A at this • Date of birth (age 24–53)
institution) • Randomize
MIT 9.008 Chronic Care OIG Q: 1.001 • Chronic care conditions (at least 1 condition per
Vaccinations IP—any risk level)
• Randomize
(25) • Condition must require vaccination(s)
MIT 9.009 Valley Fever Cocci transfer • Reports from past 2–8 months
status report • Institution
• Ineligibility date (60 days prior to inspection date)
(20) • All
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 93
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Reception Center Arrivals
MITs 12.001–008 RC SOMS • Arrival date (2–8 months)
(N/A at this • Arrived from (county jail, return from parole, etc.)
institution) • Randomize
Specialized Medical Housing
MITs 13.001–004 CTC CADDIS • Admit date (1–6 months)
• Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
(10) • Randomize
MIT 13.101 Call Buttons OIG inspector • Review by location
CTC onsite review
(all)
Specialty Services
MITs 14.001–002 High-Priority MedSATS • Approval date (3–9 months)
(15) • Randomize
MITs 14.003–004 Routine MedSATS • Approval date (3–9 months)
• Remove optometry, physical therapy or podiatry
(15) • Randomize
MIT 14.005 Specialty Services MedSATS • Arrived from (other CDCR institution)
Arrivals • Date of transfer (3–9 months)
(20) • Randomize
MIT 14.006–007 Denials InterQual • Review date (3–9 months)
(19) • Randomize
IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
(1) • Randomize
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 94
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Administrative Operations
MIT 15.001 Medical Appeals Monthly medical • Medical appeals (12 months)
(all) appeals reports
MIT 15.002 Adverse/Sentinel Adverse/sentinel • Adverse/sentinel events (2–8 months)
Events events report
(0)
MITs 15.003–004 QMC Meetings Quality • Meeting minutes (12 months)
Management
Committee
(6) meeting minutes
MIT 15.005 EMRRC EMRRC meeting • Monthly meeting minutes (6 months)
(12) minutes
MIT 15.006 LGB LGB meeting • Quarterly meeting minutes (12 months)
(4) minutes
MIT 15.101 Medical Emergency Onsite summary • Most recent full quarter
Response Drills reports & • Each watch
documentation
(3) for ER drills
MIT 15.102 2nd Level Medical Onsite list of • Medical appeals denied (6 months)
Appeals appeals/closed
(10) appeals files
MIT 15.103 Death Reports Institution-list of • Most recent 10 deaths
deaths in prior 12 • Initial death reports
(3) months
MIT 15.104 RN Review Onsite supervisor • RNs who worked in clinic or emergency setting
Evaluations periodic RN six or more days in sampled month
reviews • Randomize
(5)
MIT 15.105 Nursing Staff Onsite nursing • On duty one or more years
Validations education files • Nurse administers medications
(10) • Randomize
MIT 15.106 Provider Annual Onsite • All required performance evaluation documents
Evaluation Packets provider
(7) evaluation files
MIT 15.107 Provider licenses Current provider • Review all
listing (at start of
(9) inspection)
MIT 15.108 Medical Emergency Onsite • All staff
Response certification o Providers (ACLS)
Certifications tracking logs o Nursing (BLS/CPR)
(all) • Custody (CPR/BLS)
MIT 15.109 Nursing staff and Onsite tracking • All required licenses and certifications
Pharmacist in system, logs, or
Charge Professional employee files
Licenses and
Certifications
(all)
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 95
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Administrative Operations
MIT 15.110 Pharmacy and Onsite listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
(all) document
MIT 15.111 Nursing Staff New Nursing staff • New employees (hired within last 12 months)
Employee training logs •
Orientations
(all)
MIT 15.998 Death Review OIG summary • Between 35 business days & 12 months prior
Committee log - deaths • CCHCS death reviews
(3)
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 96
Office of the Inspector General State of California
C C
ALIFORNIA ORRECTIONAL
H C S ’
EALTH ARE ERVICES
R
ESPONSE
Pleasant Valley State Prison, Cycle 5 Medical Inspection Page 97
Office of the Inspector General State of California