OIG
Richard J. Donovan Correctional Facility Cycle 7 Medical Inspection Report
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Cycle 7, Richard J. Donovan Correctional Facility | iii
Contents
Illustrations iv
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 5
Institution-Specific Metrics 6
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 14
Access to Care 14
Diagnostic Services 21
Emergency Services 26
Health Information Management 30
Health Care Environment 36
Transfers 45
Medication Management 51
Preventive Services 58
Nursing Performance 61
Provider Performance 66
Specialized Medical Housing 71
Specialty Services 76
Administrative Operations 82
Appendix A: Methodology 85
Case Reviews 86
Compliance Testing 89
Indicator Ratings and the Overall Medical Quality Rating 90
Appendix B: Case Review Data 91
Appendix C: Compliance Sampling Methodology 94
California Correctional Health Care Services’ Response 101
November 25, 2024, OIG Response to November 15, 2024, Letter
Regarding RJD Report 102
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7, Richard J. Donovan Correctional Facility | iv
Illustrations
Tables
1. RJD Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. RJD Master Registry Data as of July 2023 7
3. RJD Health Care Staffing Resources as of July 2023 8
4. RJD Results Compared With State HEDIS Scores 10
5. Access to Care 18
6. Other Tests Related to Access to Care 19
7. Diagnostic Services 24
8. Health Information Management 33
9. Other Tests Related to Health Information Management 34
10. Health Care Environment 43
11. Transfers 48
12. Other Tests Related to Transfers 49
13. Medication Management 55
14. Other Tests Related to Medication Management 56
15. Preventive Services 59
16. Specialized Medical Housing 74
17. Specialized Services 79
18. Other Tests Related to Specialized Services 80
19. Administrative Operations 83
A–1. Case Review Definitions 86
B–1. RJD Case Review Sample Sets 91
B–2. RJD Case Review Chronic Care Diagnoses 92
B–3. RJD Case Review Events by Program 93
B–4. RJD Case Review Sample Summary 93
Figures
A–1. Inspection Indicator Review Distribution for RJD 85
A–2. Case Review Testing 88
A–3. Compliance Sampling Methodology 89
Photographs
1. Indoor Patient Waiting Area 36
2. Torn Mat 37
3. Expired Medical Supplies 38
4. Cleaning Materials Stored With Medical Supplies 39
5. Expired Medical Supplies in Medical Warehouse 40
6. Staff Restroom Was Unsanitary 40
7. Forceps Were Not Kept in Sterilized Packaging 41
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care the department provides to
its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
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As we did during Cycle 6, our office continues to inspect both those institutions
remaining under federal receivership and those delegated back to the department. There
is no difference in the standards used for assessing a delegated institution versus an
institution not yet delegated. At the time of the Cycle 7 inspection of Richard J. Donovan
Correctional Facility, the institution had not been delegated back to the department by
the receiver.
We completed our seventh inspection of the institution, and this report presents our
assessment of the health care provided at this institution during the inspection period
from December 2022 to May 2023.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between August 2022 and April 2023, anticoagulation reviews between December 2022
and May 2023, and transfer reviews between January 2023 and March 2023.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7, Richard J. Donovan Correctional Facility | 3
Summary: Ratings and Scores
We completed the Cycle 7 inspection of Richard J. Donovan Correctional Facility (RJD) in
October 2023. OIG inspectors monitored the institution’s delivery of medical care that
occurred between December 2022 and May 2023.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at RJD adequate. quality at RJD inadequate.
OIG case review clinicians (a team of physicians and nurse consultants) reviewed 67
cases, which contained 1,286 patient-related events. They performed quality control
reviews; their subsequent collective deliberations ensured consistency, accuracy, and
thoroughness. Our OIG clinicians acknowledged institutional structures that catch and
resolve mistakes that may occur throughout the delivery of care. After examining the
medical records, our clinicians completed a follow-up on-site inspection in October 2023
to verify their initial findings. OIG physicians rated the quality of care for 25
comprehensive case reviews. Of these 25 cases, our physicians rated 21 adequate and four
inadequate.
To test the institution’s policy compliance, our compliance inspectors (a team of
registered nurses) monitored the institution’s compliance with its medical policies by
answering a standardized set of questions that measure specific elements of health care
delivery. Our compliance inspectors examined 398 patient records and 1,205 data points
and used the data to answer 90 policy questions. In addition, we observed RJD’s
processes during an on-site inspection in July 2023.
The OIG then considered the results from both case review and compliance testing, and
drew overall conclusions, which we report in 13 health care indicators.5
5 The indicators for Reception Center and Prenatal and Postpartum Care did not apply to RJD.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7, Richard J. Donovan Correctional Facility | 4
We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. RJD Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies can be
minor or significant, depending on the severity of the deficiency. An adverse event occurs
when the deficiency caused harm to the patient. All major health care organizations
identify and track adverse events. We identify deficiencies and adverse events to
highlight concerns regarding the provision of care and for the benefit of the institution’s
quality improvement program to provide an impetus for improvement.6
The OIG found no adverse events at RJD during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 10 of the 13
indicators applicable to RJD. Of these 10 indicators, OIG clinicians rated none proficient,
eight adequate, and two inadequate. OIG physicians also rated the overall adequacy of
care for each of the 25 detailed case reviews they conducted. Of these 25 cases, 21 were
adequate, and four were inadequate. In the 1,286 events reviewed, we found 412
deficiencies, 66 of which the OIG clinicians considered to be of such magnitude that, if
left unaddressed, would likely contribute to patient harm.
Our clinicians found the following strengths at RJD:
• RJD performed well in providing patient access to correctional treatment
center (CTC) providers and clinic nurses as well as follow-up care after
hospitalizations and triage and treatment area (TTA) events, as medically
indicated.
Our clinicians found the following areas needing improvement at RJD:
• Nurses did not always document complete and relevant assessments of
wound care and feeding tube interventions for patients in the specialized
medical housing (SMH).
• Nurses performed poorly when responding to emergency medical alarms in
their assessments, interventions, and plans of care.
• RJD nursing leadership often did not identify opportunities for improvement
during Emergency Medical Response Review Committee (EMRRC) reviews.
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable to RJD. Of these 10
indicators, our compliance inspectors rated one proficient, none adequate, and nine
inadequate. We tested policy compliance in the Health Care Environment, Preventative
6 For a further discussion of an adverse event, see Table A–1.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7, Richard J. Donovan Correctional Facility | 6
Services, and Administrative Operations as these indicators do not have a case review
component.
RJD showed a high rate of policy compliance in the following areas:
• Staff performed excellently in scanning health care services request forms,
specialty service reports, and community hospital discharge reports.
• Nurses at RJD reviewed health care services request forms and conducted
face-to-face encounters within required time frames.
• Staff performed well in providing preventive services for patients, such as
influenza vaccinations, annual testing for tuberculosis (TB), and colorectal
cancer screenings.
RJD showed a low rate of policy compliance in the following areas:
• Medical warehouse and clinics had multiple expired medical supplies.
• Clinical staff did not consistently follow universal hand hygiene precautions
before or after patient encounters.
• Nursing staff did not regularly inspect emergency response bags.
• Staff did not perform well in ensuring approved specialty services were
provided within specified time frames.
• Patients did not always receive medications within the required time frames.
These included newly ordered medications, chronic care medications,
medications for patients returning from hospitalization, medications for
patients admitted to specialized medical housing, medications for patients
transferring within the facility, and medications for patients laying over at
RJD.
Institution-Specific Metrics
Richard J. Donovan Correctional Facility (RJD) is in unincorporated San Diego County,
near San Diego, and is approximately one and a half miles from the Mexico–United States
border. The institution, which opened in July 1987, provides housing for general
population and levels I, II, III, and IV incarcerated persons. The department designated
RJD for incarcerated persons with severe mental illnesses as well as incarcerated persons
with developmental disabilities. RJD has multiple clinics in which medical staff respond
to nonurgent requests for medical services and a triage and treatment area (TTA) to
provide urgent and emergent care. The facility has a licensed correctional treatment
center (CTC) to provide health care to patients who need supervised health care beyond
what is normally provided on an outpatient basis. The department has also designated
RJD as an intermediate care institution. Intermediate institutions are located in
predominantly urban areas, close to tertiary care centers and specialty care providers, for
the most cost-effective care.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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As of July 18, 2024, the department reported on its public tracker 85 percent of RJD’s
incarcerated population was fully vaccinated for COVID-19 while 64 percent of RJD’s
staff was fully vaccinated for COVID-19.7
In July 2023, the Health Care Services Master Registry showed RJD had a total population
of 3,071. A breakdown of the medical risk level of the RJD population as determined by
the department is set forth in Table 2 below.8
Table 2. RJD Master Registry Data as of July 2023
Medical Risk Level Number of Patients Percentage*
High 1 781 25.4%
High 2 691 22.5%
Medium 1,297 42.2%
Low 302 9.8%
Total 3,071 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from
the CCHCS Master Registry dated 07-17-23.
7 For more information, see the department’s statistics on its website page titled Population COVID-19
Tracking.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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According to staffing data the OIG obtained from California Correctional Health Care
Services (CCHCS), as identified in Table 3 below, RJD had no vacant executive leadership
positions, no primary care provider vacancies, no nursing supervisor vacancies, and no
nursing staff vacancies.
Table 3. RJD Health Care Staffing Resources as of July 2023
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 7.0 15.5 26.7 184.7 233.9
Filled by Civil Service 8.0 16.5 24.5 154.8 203.8
Vacant 0 0 2.2 29.9 32.1
Percentage Filled by Civil Service 114.3% 106.5% 91.8% 83.8% 87.1%
Filled by Telemedicine 0 0 0 2.0 2.0
Percentage Filled by Telemedicine 0 0 0 1.1% 0.9%
Filled by Registry 0 2.5 0 55.0 57.5
Percentage Filled by Registry 0 16.1% 0 29.8% 24.6%
Total Filled Positions 8.0 19.0 24.5 211.8 263.3
Total Percentage Filled 114.3% 122.6% 91.8% 114.7% 112.6%
Appointments in Last 12 Months 0 0 4.0 15.0 19.0
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 1.0 16.0 17.0
Adjusted Total: Filled Positions 8.0 19.0 23.5 195.8 246.3
Adjusted Total: Percentage Filled 114.3% 122.6% 88.0% 106.0% 105.3%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes the classifications of Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Notes: The OIG does not independently validate staffing data received from the department. Positions are based on
fractional time-base equivalents.
Source: Cycle 7 medical inspection preinspection questionnaire received on July 17, 2023, from California Correctional
Health Care Services.
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Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted above, the OIG
presents selected measures from the Healthcare Effectiveness Data and Information Set
(HEDIS) for comparison purposes. The HEDIS is a set of standardized quantitative
performance measures designed by the National Committee for Quality Assurance to
ensure the public has the data it needs to compare the performance of health care plans.
Because the Veterans Administration no longer publishes its individual HEDIS scores,
we removed them from our comparison for Cycle 7. Likewise, Kaiser (commercial plan)
no longer publishes HEDIS scores. However, through the California Department of
Health Care Services’ Medi‑Cal Managed Care Technical Report, the OIG obtained
California Medi-Cal and Kaiser Medi-Cal HEDIS scores to use in conducting our
analysis, and we present them here for comparison.
HEDIS Results
We considered RJD’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. Currently, only two HEDIS
measures are available for review: poor HbA1c control, which measures the percentage of
diabetic patients who have poor blood sugar control, and colorectal cancer screening
rates for patients ages 45 to 75. For poor HBA1c control, RJD’s results compared
favorably with those found in State health plans. We list the applicable HEDIS measures
in Table 4.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)— RJD’s
percentage of patients with poor HbA1c control was significantly lower, indicating very
good performance on this measure.
Immunizations
Statewide comparative data were not available for immunization measures; however, we
include these data for informational purposes. RJD had a 54 percent influenza
immunization rate for adults 18 to 64 years old and a 69 percent influenza immunization
rate for adults 65 years of age and older.9 The pneumococcal vaccination rate was
92 percent.10
Cancer Screening
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)— RJD’s
9 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable result.
10 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines (PCV13,
PCV15, and PCV20), or 23 valent pneumococcal vaccine (PPSV23), depending on the patient’s medical
conditions. For the adult population, the influenza or pneumococcal vaccine may have been administered at a
different institution other than where the patient was currently housed during the inspection period.
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Cycle 7, Richard J. Donovan Correctional Facility | 10
colorectal cancer screening rate of 71 percent was higher, indicating very good
performance on this measure.
Table 4. RJD Results Compared With State HEDIS Scores
RJD California California
Kaiser Kaiser
Cycle 7 California NorCal SoCal
HEDIS Measure Results * Medi-Cal † Medi-Cal † Medi-Cal †
HbA1c Screening 100% – – –
Poor HbA1c Control (> 9.0%) ‡,§ 6% 36% 31% 22%
HbA1c Control (< 8.0%) ‡ 86% – – –
Blood Pressure Control (< 140/90) ‡ 90% – – –
Eye Examinations 58% – – –
Influenza – Adults (18 – 64) 54% – – –
Influenza – Adults (65 +) 69% – – –
Pneumococcal – Adults (65 +) 92% – – –
Colorectal Cancer Screening 71% 37% 68% 70%
Notes and Sources
* Unless otherwise stated, data were collected in July 2023 by reviewing medical records from a sample of
RJD’s population of applicable patients. These random statistical sample sizes were based on a 95 percent
confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication
Medi-Cal Managed Care External Quality Review Technical Report, dated July 1, 2022–June 30, 2023
(published March - April 2024); https://www.dhcs.ca.gov/dataandstats/reports/Documents/Medi-Cal-
Managed-Care-Technical-Report-Volume-1.pdf
‡ For this indicator, the entire applicable RJD population was tested.
§ For this measure only, a lower score is better.
Source: Institution information provided by the California Department of Corrections and Rehabilitation.
Health care plan data were obtained from the CCHCS Master Registry.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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Recommendations
As a result of our assessment of RJD’s performance, we offer the following
recommendations to the department:
Access to Care
• Medical leadership should ensure patients with chronic care conditions and
patients transferring from another state institution are timely seen by the
provider and should implement remedial measures as appropriate.
• Medical leadership should determine the root cause of untimely sick call
follow-up appointments with clinic providers and should implement
remedial measures as appropriate.
Diagnostic Services
• Medical leadership should determine the root causes of challenges to the
notification and the endorsement of anticoagulation laboratory results and
should implement remedial measures as appropriate to ensure all laboratory
tests are reviewed and signed by the providers who ordered the tests.
• The department should consider developing strategies to ensure providers
create patient letters when they endorse test results and ensure patient
letters contain all elements required by CCHCS policy.
• Medical leadership should ascertain causative factors related to the untimely
collection of laboratory specimens and implement remedial measures as
appropriate.
Emergency Services
• Nursing leadership should determine the challenges to ensuring nursing
staff complete thorough assessments and provide appropriate interventions
and documentation in emergent and urgent events. Leadership should
implement remedial measures as appropriate.
• The chief nurse executive (CNE) and the chief medical executive (CME), or
their designees, should identify and implement strategies to perform
thorough clinical reviews of emergent events and identify opportunities for
improvement or training issues as appropriate.
Health Care Environment
• Medical leadership should determine the root cause for staff not following all
required universal hand hygiene precautions and take necessary remedial
measures.
• Nursing leadership should determine the root cause for staff not ensuring
clinic examination rooms contain essential core medical equipment. The
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Cycle 7, Richard J. Donovan Correctional Facility | 12
leadership should also verify staff follow equipment and medical supply
management protocols and should take necessary remedial measures.
• Executive leadership should determine the root cause for staff not ensuring
reusable noninvasive medical equipment is properly disinfected and take
necessary remedial measures.
• Nursing leadership should determine the root causes for staff either not
ensuring the EMRBs are regularly inventoried and sealed or not properly
completing monthly logs and should implement all necessary remedial
measures.
Transfers
• Nursing leadership should develop and implement internal auditing of staff
to ensure complete and thorough assessments of patients returning from
hospitalizations and should implement remedial measures as appropriate.
• Nursing leadership should identify the root causes for R&R nurses not
completing the initial health care screening, including answering all
questions and documenting an explanation for each “yes” answer; not
documenting a complete set of vital signs as part of the patient’s initial
health care screening assessment; and not completing the initial health care
screening form prior to the patient being placed in housing. Nursing
leadership should implement remedial measures as appropriate.
Medication Management
• Medical and nursing leadership should ensure chronic care, hospital
discharge, and en route patients receive their medications timely and without
interruption; leadership should implement remedial measures as appropriate.
• The institution should consider developing and implementing measures to
ensure staff timely make available and administer medications to patients as
described in CCHCS policy and procedures.
• Nursing leadership should consider developing and implementing measures
to ensure nursing staff document patients’ refusal reasons and no-shows on
MAR summaries, in accordance with CCHCS’ policies and procedures.
Preventive Services
• Nursing leadership should consider developing and implementing measures
to ensure nursing staff consistently perform patient monitoring, as described
in CCHCS care guides, and nursing staff completely address TB signs and
symptoms in their patient monitoring.
• Medical leadership should determine the root cause of challenges in the
timely provisions of vaccinations to chronic care patients and implement
remedial measures as appropriate.
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Nursing Performance
• Nursing leadership should determine the challenges to ensuring nursing
staff complete thorough assessments, provide appropriate interventions, and
thoroughly document encounters. Leadership should implement remedial
measures as appropriate.
• Nursing leadership should develop and implement measures to assess the
clinical quality of nursing care, in addition to the current compliance audits,
and should provide training and education as necessary.
Provider Performance
• Medical leadership should develop and implement monitoring strategies to
ensure providers follow medical provider documentation expectations
according to the department’s HCDOM and RJD LOP.11
Specialized Medical Housing
• Nursing leadership should determine the challenges to ensuring
nursing staff complete thorough documentation of wound care
assessments, including clinical appearance of the wound,
surrounding tissue, and measurements. Leadership should
implement remedial measures as appropriate.
• Nursing leadership should ensure nursing staff completes initial
assessments within the time frame required by CCHCS policy.
Specialty Services
• Medical leadership should determine the root causes of challenges to the
timely provision of specialty services with high-priority referrals as well as
their subsequent high-priority specialty follow-up appointments and should
implement remedial measures as appropriate.
• The department should consider developing and implementing measures to
ensure institutions timely receive the medium- and routine-priority specialty
reports, and providers timely review these reports.
• Medical leadership should identify the root cause of challenges to the timely
provision of preapproved specialty appointments for transfer-in patients and
should implement remedial measures as appropriate.
11 HCDOM is the Health Care Department Operations Manual. LOP is the local operating policy.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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Indicators
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing
patients with timely clinical appointments. Our inspectors reviewed scheduling and
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
specialists. Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (73.0%)
As in Cycle 6, case review found RJD provided sufficient access to care. Case reviewers
found appointments with clinic providers and nurses were generally completed timely.
Patients had good access to correctional treatment center (CTC) providers, sick call
nurses, specialty services, and follow-up appointments with providers after specialty
services. Factoring in all aspects of care, the OIG rated the case review component of this
indicator adequate.
Compliance testing showed RJD had mixed results in access to care. Staff performed
excellently in reviewing patient sick call requests, completing face-to-face encounters,
and ensuring provider follow-up appointments after returning from hospitalizations.
However, compliance testing resulted in low scores for provider follow-up appointments
for patients with chronic care conditions and for patients transferring into the
institution. Based on the overall compliance score result, the OIG rated the compliance
component of this indicator inadequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 282 provider, nursing, urgent or emergent care (TTA), specialty,
and hospital events that required the institution to generate appointments. We identified
20 deficiencies related to access to care, six of which were significant.12
Access to Care Providers
Access to clinic providers is an integral part of patient care in health care delivery. RJD
had a mixed performance in providing chronic care follow-up appointments with clinic
providers. Compliance testing showed chronic care face-to-face follow-up appointments
and nurse-to-provider follow-up appointments occurred within required time frames less
than half of the time (MIT 1.001, 44.0% and MIT 1.005, 46.7%). However, sick call follow-
up appointments with nurses always occurred timely (MIT 1.006, 100%).
12 Deficiencies occurred in cases 1, 11, 13, 21, 23, 26, 28, 29, 32, 46, 60, 66, and 67. Significant deficiencies
occurred in cases 13, 21, 28, 29, and 32.
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Due to movement restrictions related to the COVID-19 pandemic, we considered most
cases of provider chart reviews to have been triage of nonurgent, low-, or medium-risk
chronic care appointments and an acceptable alternative to face-to-face or telephonic
encounters. OIG clinicians reviewed 127 clinic provider encounters and identified one
deficiency:
• In case 13, the provider ordered an episodic medical follow-up appointment,
which occurred five days late.
Access to Specialized Medical Housing Providers
RJD performed well in providing access to CTC providers. Compliance testing showed
RJD almost always completed written history and physical examinations of patients
admitted to the CTC within the required time frame (MIT 13.002, 90.0%). Our clinicians
did not identify any deficiencies regarding patients’ access to CTC providers.
Access to Clinic Nurses
RJD performed well in providing access to nursing sick calls and provider-to-nurse
referrals. Compliance testing showed all nursing sick call requests were reviewed on the
same day they were received (MIT 1.003, 100%), and nurses always completed face-to-face
appointments within one day after triaging the sick call requests (MIT 1.004, 100%). Our
clinicians reviewed 74 nursing sick call triage encounters and identified two deficiencies
related to clinic nurse access:
• In case 21, a nurse reviewed a patient sick call submission and requested an
appointment to occur the next day. However, the appointment was scheduled
two days late.
• In case 46, a nurse performed sick call triage for two sick call requests from
the patient. The nurse documented the patient as an “add on” to be seen on
the same day, but the patient was not evaluated until the following day.
Access to Specialty Services
RJD had a mixed performance in access to specialty services. Compliance testing showed
initial high-priority, medium-priority, routine-priority, and specialty appointments
intermittently occurred within required time frames (MIT 14.001, 60.0%, MIT 14.004,
73.3%, and MIT 14.007, 73.3%). The institution also had variable results with follow-up
specialty appointments. Compliance testing showed subsequent high-priority and
medium-priority follow-up specialty appointments only sometimes occurred within
required time frames (MIT 14.003, 57.1% and MIT 14.006, 61.5%); however, subsequent
routine-priority specialty service appointments always occurred within the required time
frame (MIT 14.009, 100%). Our clinicians reviewed 161 specialty service events and
identified six deficiencies, two of which were significant.13 The following are examples:
• In case 29, the neurosurgery specialist assessed the patient. The provider
reviewed the specialist’s report and requested a high-priority referral for an
13 Deficiencies occurred in cases 23, 26, 29, and 67. Significant deficiencies occurred in case 29.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7, Richard J. Donovan Correctional Facility | 16
MRI of the lumbar spine. However, the MRI was completed over three
months later.14
• In addition, in case 29, the provider assessed the patient following an initial
consult with the neurosurgeon and ordered a referral for a follow-up with the
neurosurgery specialist. However, the appointment with the specialist did
not occur timely during the review period.
Follow-Up After Specialty Services
RJD’s performance was only fair in ensuring providers evaluated their patients within the
required time frame after specialty appointments. Compliance testing showed provider
appointments after specialty services usually occurred within the required time frame
(MIT 1.008, 78.1%). OIG clinicians identified one significant delayed provider
appointment:
• In case 28, after the high-priority specialty services appointment, the nursing
staff scheduled a provider follow-up appointment to occur within 14 days,
instead of five calendar days.
Follow-Up After Hospitalization
RJD performed well in ensuring providers evaluated their patients within required time
frames after hospitalizations. Compliance testing showed provider appointments after
hospitalization generally occurred within required the time frame (MIT 1.007, 88.0%).
OIG clinicians reviewed 30 hospital returns and did not identify any missed or delayed
appointments.
Follow-Up After Urgent or Emergent Care (TTA)
Providers always evaluated their patients following triage and treatment area (TTA)
events as medically indicated. OIG clinicians assessed 10 TTA events and did not identify
any delayed or missed provider follow-up appointments.
Follow-Up After Transferring Into RJD
Access to care for patients who had recently transferred into the institution was mixed.
Compliance testing showed poor access for intake appointments of newly arrived
patients (MIT 1.002, 50.0%). OIG clinicians reviewed three transfer-in cases and found
one significant deficiency:
• In case 32, when the patient transferred to RJD, the provider documented the
patient was checked in for his scheduled interfacility transfer-in
appointment, including MAT discussion; however, the patient left before the
appointment occurred and was, thus, not seen.15 The provider also
14 An MRI is a magnetic resonance imaging scan.
15 MAT is the Medication Assisted Treatment program for substance use disorder.
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Cycle 7, Richard J. Donovan Correctional Facility | 17
documented the patient would be rescheduled. However, the patient was not
seen until six weeks after the patient transferred into RJD.
Clinician On-Site Inspection
At the time of our inspection, RJD had the following clinics: A Clinic, B Clinic, C Clinic,
D Clinic, E Clinic, ASU Clinic, EOP Clinic, the TTA, and the CTC. Each clinic was
assigned one to three medical providers to care for patients. RJD also provided on-site
specialty services for optometry, ophthalmology, audiology, physical therapy, podiatry,
and a kidney dialysis unit. The nursing manager reported a nephrologist came on site
weekly, and up to eight dialysis beds were operating, again at the time of our inspection.
OIG clinicians attended morning huddles and provider meetings, including medical
subcommittee meetings, which were well attended. Medical leadership reported each
clinic, in general, arranged 12 appointments per day for each provider: 10 scheduled and
two left available for open access to accommodate same-day appointments. The office
technician reported experiencing challenges in obtaining off-site specialty appointments.
Medical leadership reported having vacancies for one provider and one registry provider.
Compliance On-Site Inspection
Three of six housing units randomly tested at the time of inspection had access to health
care services request forms (CDCR form 7362) (MIT 1.101, 50.0%). In two housing units,
custody officers did not have a system in place for restocking the forms. The custody
officers reported relying on medical staff to replenish the forms in the housing units. We
also found one housing unit that did not have a supply of CDCR form 7362 available.
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Cycle 7, Richard J. Donovan Correctional Facility | 18
Compliance Score Results
Table 5. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent chronic
care visit within the health care guideline’s maximum allowable interval or 11 14 0 44.0%
within the ordered time frame, whichever is shorter? (1.001)
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 11 11 3 50.0%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
35 0 0 100%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
35 0 0 100%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
7 8 20 46.7%
maximum allowable time or the ordered time frame, whichever is the
shorter? (1.005)
Sick call follow-up appointments: If the primary care provider ordered a
follow-up sick call appointment, did it take place within the time frame 1 0 34 100%
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
22 3 0 88.0%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
32 9 4 78.1%
occur within required time frames? (1.008) *
Clinical appointments: Do patients have a standardized process to obtain
3 3 0 50.0%
and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 73.0%
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Richard J. Donovan Correctional Facility | 19
Table 6. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the N/A N/A N/A N/A
required time frame? (12.003)
For patients received from a county jail: Did the patient receive a history
and physical by a primary care provider within seven calendar days (prior N/A N/A N/A N/A
to 07/2022) or five working days (effective 07/2022)? (12.004)
Was a written history and physical examination completed within the
9 1 0 90.0%
required time frame? (13.002)
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 9 6 0 60.0%
Request for Service? (14.001)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 4 3 8 57.1%
provider? (14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or the Physician Request 11 4 0 73.3%
for Service? (14.004)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 8 5 2 61.5%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 11 4 0 73.3%
for Service? (14.007)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care 9 0 6 100%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Richard J. Donovan Correctional Facility | 20
Recommendations
• Medical leadership should ensure patients with chronic care conditions and
patients transferring from another state institution are timely seen by the
provider and should implement remedial measures as appropriate.
• Medical leadership should determine the root cause of untimely sick call
follow-up appointments with clinic providers and should implement
remedial measures as appropriate.
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Cycle 7, Richard J. Donovan Correctional Facility | 21
Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s performance in timely
completing radiology, laboratory, and pathology tests. Our inspectors determined
whether the institution properly retrieved the resultant reports and whether providers
reviewed the results correctly. In addition, in Cycle 7, we examined the institution’s
performance in timely completing and reviewing immediate (STAT) laboratory tests.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (57.7%)
As in Cycle 6, case review found RJD delivered a good performance in this indicator. Staff
generally completed laboratory testing within required time frames. Staff also retrieved,
and providers endorsed, these results timely. However, case review found opportunities
for improvement in timely providing on-site special imaging services (ultrasound)
appointments to patients. After reviewing all aspects, the OIG rated the case review
component of this indicator adequate.
Compliance testing was mixed in this indicator. RJD performed well in reviewing and
endorsing diagnostic test results. However, staff performed poorly in providing and
notifying patients of diagnostic test results and generating patient letters with all
required key elements. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 219 diagnostic events and found 99 deficiencies, four of which were
significant.16 Of these 99 deficiencies, we found 91 related to health information
management and six pertained to the delay in completing diagnostic tests.
For health information management, we consider test reports that were never retrieved
or reviewed to be as severe a problem as tests that were never performed. We discuss this
further in the Health Information Management indicator.
Test Completion
RJD had variable performance in completing diagnostic tests. In compliance testing, staff
performed very well in completing radiology services within required time frames (MIT
2.001, 90.0%), but needed to improve in completing laboratory tests (MIT 2.004, 50.0%).
16 Deficiencies occurred in cases 2, 3, 9–18, 20–24, 26–30, 66, and 67. Significant deficiencies occurred in cases
12, 21, and 26.
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OIG clinicians reviewed 26 radiology imaging studies and 188 laboratory tests and found
seven deficiencies, one of which was significant.17 The following are examples:
• In case 21, the provider ordered an abdominal ultrasound to be performed
within 45 days for cancer surveillance. However, the ultrasound was not
performed during the review period.
• In case 26, the provider ordered an urgent carotid ultrasound. However, the
study was performed over two months later.
Neither case review nor compliance testing had any STAT laboratory tests in their samples
(MIT 2.007, N/A).
Health Information Management
RJD staff often retrieved laboratory and diagnostic results promptly and sent them to
providers for review. Compliance testing showed providers almost always endorsed
radiology and always endorsed laboratory results timely (MIT 2.002, 90.0% and MIT 2.005,
100%).
RJD performed poorly in communicating test results with letters to patients. Compliance
testing showed providers scored very low in communicating complete letters for
radiology, laboratory, and pathology test results to the patients (MIT 2.003, 30.0%, MIT
2.006, 10.0%, and MIT 2.012, zero). Similarly, OIG clinicians identified 90 deficiencies; 81
related to patient test results notification letters, 60 of which were due to missing
elements in the letters.18 19 Additionally, one deficiency related to a delay in scanning.20
The following are examples:
• In case 21, the pathology results from an off-site esophago-
gastroduodenoscopy (EGD) biopsy were scanned into the electronic health
record system (EHRS) over two months late.21
• In case 24, the provider endorsed the laboratory test results and created a
patient notification letter. However, the letter did not indicate whether the
results were within normal limits.
We identified seven deficiencies in which staff did not forward test results to a provider
for endorsement.22 The following are examples:
• In case 12, the patient had anticoagulation tests, and the results became
available the next day. However, no provider reviewed or signed the results
for the patient.
17 Deficiencies occurred in cases 26, 66, and 67. A significant deficiency occurred in case 26.
18 Deficiencies occurred in cases 2, 3, 9–18, 20–24, and 26–30.
19 Deficiencies occurred in cases 2, 3, 9–14, 16–18, 20–24, and 26–30.
20 This significant deficiency occurred in case 21
21 In this procedure, the specialist uses a camera to examine the esophagus and the stomach.
22 Deficiencies occurred in cases 12–14.
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Cycle 7, Richard J. Donovan Correctional Facility | 23
• In case 14, the patient had a laboratory anticoagulation test, and the result
became available the next day. However, the results were not forwarded to a
provider for endorsement.
Clinician On-Site Inspection
OIG clinicians met with laboratory and radiology staff. RJD provided on-site mobile CT,
MRI, and ultrasound imaging services as well as on-site general x-ray services.23 The
senior radiologic technologist reported challenges in scheduling patients with an
external mobile imaging vendor due to technician shortages, which resulted in frequent
rescheduled appointments. At the time of our inspection, an external laboratory vendor
was providing laboratory and pathology diagnostic services for the institution. After the
vendor processed the laboratory and pathology specimens, the laboratory and pathology
results interfaced directly into patients’ electronic health records for the institution’s
health care teams to review. The laboratory technician reported any critical laboratory
results were communicated through TTA staff directly by the vendor.
23 A CT scan is a computed, or computerized, tomography imaging scan. CT, MRI, and ultrasound scans are
types of advanced diagnostic tools that allow medical practitioners to visualize the internal structures of the
body.
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Cycle 7, Richard J. Donovan Correctional Facility | 24
Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
9 1 0 90.0%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
3 7 0 30.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
5 5 0 50.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
10 0 0 100%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
1 9 0 10.0%
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
N/A N/A N/A N/A
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frames? (2.008)
Laboratory: Did the health care provider endorse the STAT laboratory
N/A N/A N/A N/A
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within the
6 4 0 60.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
8 1 1 88.9%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 9 1 0
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 57.7%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Richard J. Donovan Correctional Facility | 25
Recommendations
• Medical leadership should determine the root causes of challenges to the
notification and the endorsement of anticoagulation laboratory results and
should implement remedial measures as appropriate to ensure all laboratory
tests are reviewed and signed by the providers who ordered the tests.
• The department should consider developing strategies to ensure providers
create patient letters when they endorse test results and patient letters
contain all elements required by CCHCS policy.
• Medical leadership should ascertain causative factors related to the untimely
collection of laboratory specimens and implement remedial measures as
appropriate.
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Cycle 7, Richard J. Donovan Correctional Facility | 26
Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed emergency medical services by examining the timeliness and
appropriateness of clinical decisions made during medical emergencies. Our evaluation
included examining the emergency medical response, cardiopulmonary resuscitation
(CPR) quality, triage and treatment area (TTA) care, provider performance, and nursing
performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services.
The OIG assessed the institution’s emergency services mainly through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
Case review found RJD needed improvement in this indicator. RJD nurses performed
poorly in emergency services. We identified opportunities for improvement when nurses
responded to medical alarms as well as for nursing assessments, interventions, and plans
of care. In addition, when the institution’s chief nurse executive (CNE) and chief medical
executive (CME) or designees conducted clinical reviews, they frequently did not identify
their staff’s deficiencies. Furthermore, compared with Cycle 6, RJD had more overall and
significant deficiencies. The OIG rated this indicator inadequate.
Case Review Results
We reviewed 47 urgent and emergent events and found 65 emergency care deficiencies.
Of these 65 deficiencies, 15 were significant.24
Emergency Medical Response
RJD staff usually responded promptly to emergencies throughout the institution.
However, on one occasion, a custody officer did not have the correct keys to the
emergency response vehicle, which led to a delay in the medical staff response.
Cardiopulmonary Resuscitation Quality
During this period, we reviewed seven cases in which CPR was initiated.25 In each case,
custody staff initiated CPR, and either custody or nursing staff administered naloxone.
On three occasions, nurses responded to emergency medical alarms, and upon their
arrival, they found custody staff performing CPR; however, nurses did not immediately
attach an automated external defibrillator (AED) to patients who did not have a pulse or
document reasons for why this did not occur. Moreover, nurses did not thoroughly
24 Deficiencies occurred in cases 1–11, 23–26, 29, and 65. Significant deficiencies occurred in cases 2, 4, 6, 10, 11,
and 23.
25 Staff performed CPR in cases 4–10.
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Cycle 7, Richard J. Donovan Correctional Facility | 27
document the AED activity, and we found no AED printed activity scanned in the EHRS.
An example of nurses’ delayed AED application is given below:
• In case 4, two nurses responded to a medical alarm. On their arrival, they
found custody staff performing CPR; however, staff did not attach an AED to
the patient until six minutes after the nurses had arrived.
Provider Performance
Providers performed well in urgent and emergent situations as well as in after-hours care.
However, at times, providers did not document communication and recommendations
provided to nurses. Examples are detailed below:
• In case 11, a nurse documented consulting with a provider and receiving
orders for a medication; however, the provider did not document having
communicated with the nurse. We identified similar findings in cases 2, 23,
and 28.
Nursing Performance
Although, RJD nurses timely evaluated their patients, we found opportunities for
improvement in the areas of assessment, interventions, and documentation. We also
identified a pattern of incomplete initial assessments prepared by responding licensed
vocational nurses (LVNs). We identified 30 nursing deficiencies, eight of which were
significant. Examples are detailed below:
• In case 2, the patient had chest pains. A provider ordered nitroglycerin and
aspirin; the patient continued to complain of chest pains, but the nurse did
not administer these prescribed medications.
• In case 10, the patient had an altered level of consciousness, an elevated
pulse, and a decreased oxygen saturation. The registered nurse (RN) did not
perform an independent assessment and did not recheck the vital signs
before the patient was released to housing.
• In case 11, staff initiated a medical alarm. An LVN responded and
documented the patient had slow, shallow breaths, but the LVN did not
palpate the patient’s carotid or femoral pulse. We identified similar
deficiencies in cases 8 and 10.
• In case 25, the patient had shortness of breath and abnormal breath sounds.
A nurse administered a breathing treatment but did not objectively or
subjectively assess if the treatment was effective.
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Nursing Documentation
Nurses in the TTA often provided thorough documentation for emergent events.
However, at times, nurses’ documentation was missing information or offered conflicting
information.26 Examples are listed below:
• In case 5, an RN documented the patient’s vital signs were obtained after the
patient had left the institution.
• In case 23, an RN documented the patient’s oxygen saturation rate was
obtained using a right finger but did not document the results.
Emergency Medical Response Review Committee
Our clinicians reviewed 30 events that warranted clinical reviews and found RJD’s CNE
and CME, or their designees, did not conduct clinical reviews of six events. In addition,
in 14 events in which clinical reviews were completed, the CNE and the CME, or their
designees, did not identify opportunities for improvement in nursing or provider
performance the OIG clinicians identified.27
Compliance testing found a pervasive pattern of incomplete checklists, missing entries,
and missing time documentation (MIT 15.003, zero).
Clinician On-Site Inspection
At RJD, the TTA had four bays, two of which were larger compared with the other two
bays. The overnight shift was staffed with three RNs. The day shift was staffed with five
RNs and one LVN. The TTA staff reported two RNs on the day shift were specifically
assigned to respond to emergencies on E Yard. However, they were stationed in the main
TTA, as the E Yard did not have a TTA. RJD staff also reported they had two emergency
medical response vehicles (EMRV) to which one driver is always assigned to each vehicle;
the officer assigned to the TTA desk served as a back-up driver.
During our on-site inspection, the TTA nurses indicated they had about 80 patient
encounters a day. In addition, nursing leadership indicated having had an average of
1,481 medical emergency responses per month between January 2023 and September
2023.
OIG clinicians interviewed TTA nurses. These nurses were concerned with safety and
indicated morale was poor. They also stated custody staff did not always search patients
for weapons prior to the patients entering the TTA. In addition, nurses indicated patients
were issued intranasal naloxone that contained a needle within the device, and they
reported their concerns the needle could be accessed and altered by the patients for
unintended, nonprescribed uses.
26 Documentation deficiencies occurred in cases 1, 2, 4, 5, 8, 10, 23, and 26.
27 The CNE and the CME, or their designees, did not conduct clinical reviews in cases 2, 7, 10, 23, 26, and 65.
RJD committee’s clinical reviews did not identify opportunities for improvement in cases 1, 2, 4, 6, 8-11, 23, 24,
and 26.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7, Richard J. Donovan Correctional Facility | 29
Recommendations
• Nursing leadership should determine the challenges to ensuring nursing
staff complete thorough assessments and provide appropriate interventions
and documentation in emergent and urgent events. Leadership should
implement remedial measures as appropriate.
• The CNE and the CME, or their designees, should identify and implement
strategies to perform thorough clinical reviews of the emergent events and
identify opportunities for improvement or training issues as appropriate.
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7, Richard J. Donovan Correctional Facility | 30
Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link
in high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (88.0%)
Case review found RJD performed well in health information management. RJD staff
performed very well in retrieving and scanning hospital discharge reports as well as in
documenting urgent and emergent events. However, case review found opportunities for
improvement in providers communicating diagnostic test results to patients with
notification letters containing complete information as well as in staff retrieving and
scanning specialty reports timely. Factoring in all aspects, the OIG rated the case review
component of this indicator adequate.
Compliance testing showed RJD performed very well in this indicator. Staff’s performed
excellently in scanning patient health care services request forms and specialty
documents. In addition, staff frequently retrieved, scanned, and endorsed hospital
records and generally scanned medical records into the correct patient files. Based on the
overall compliance score result, the OIG rated the compliance component of this
indicator proficient.
Case Review and Compliance Testing Results
We reviewed 1,288 events and found 126 deficiencies related to health information
management, five of which were significant.28
Hospital Discharge Reports
RJD handled hospital discharge reports well. In compliance testing, RJD staff
performed satisfactorily in timely retrieving and scanning hospital discharge
documents into patients’ electronic health records (MIT 4.003, 80.0%). Most hospital
discharge reports contained physician discharge summaries, and providers reviewed
these reports timely (MIT 4.005, 84.0%). OIG clinicians reviewed 30 off-site
28 Deficiencies occurred in cases 2-6, 9-18, 20-24, 26-30, and 67. Significant deficiencies occurred in cases 21, 23,
26, and 29.
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Cycle 7, Richard J. Donovan Correctional Facility | 31
emergency department and hospital encounters and identified four deficiencies, none
of which were significant.29 An example is listed below:
• In case 9, the patient was seen at an emergency department for an evaluation.
RJD staff scanned the emergency department report three days late.
Specialty Reports
For the most part, RJD staff performed well in retrieving and reviewing specialty reports.
Compliance testing showed almost all specialty reports were scanned into the electronic
health record within required time frames (MIT 4.002, 96.7%). Staff performed well in
retrieving and reviewing high-priority specialty service consultant reports timely (MIT
14.002, 85.7%). However, RJD showed room for improvement in retrieving and reviewing
medium-priority and routine-priority specialty-service consultant reports timely (MIT
14.005, 71.4% and MIT 14.008, 61.5%). Our clinicians reviewed 122 specialty reports and
identified 22 deficiencies, four of which were significant.30 The following is an example:
• In case 26, a 24-hour Holter monitor test was completed, but RJD staff did
not scan the report into the electronic health record until over two months
later.
We discuss specialty reports further in the Specialty Services Indicator.
Diagnostic Reports
RJD performed satisfactorily in retrieving and endorsing diagnostic reports timely.
Compliance testing showed providers almost always endorsed radiology and always
endorsed laboratory reports within required time frames (MIT 2.002, 90.0% and MIT
2.005, 100%). However, staff could improve in ensuring they receive final pathology study
reports within the required time frame (MIT 2.010, 60.0%). Providers often reviewed and
endorsed pathology reports within required time frames (MIT 2.011, 88.9%) but never sent
complete pathology result letters to patients (MIT 2.012, zero). Our clinicians
identified 91 deficiencies, none of which were significant.31 Of those 91 deficiencies, 83
related to incomplete, or failures to create, patient test results notification letters.
Compliance testing and case review did not have any STAT laboratory tests in the testing
or review samples.
The Diagnostic Services indicator provides more details on RJD’s diagnostic services
performance.
Urgent and Emergent Records
OIG clinicians reviewed 47 emergency care events. Providers recorded their emergency
care sufficiently, including off-site telephone encounters. OIG clinicians found three
29 Deficiencies occurred in cases 3, 9, and 11.
30 Deficiencies occurred in cases 2, 14, 17, 20, 22–24, and 26–29. Significant deficiencies occurred in cases 23, 26,
and 29.
31 Deficiencies occurred in cases 2, 3, 9–18, 20–24, and 26–30. A significant deficiency occurred in case 21.
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Cycle 7, Richard J. Donovan Correctional Facility | 32
deficiencies in provider documentation.32 The following is an example of a provider
deficiency:
• In case 2, the patient with left-side chest pain at rest and with activity arrived
at the TTA for further evaluation. The TTA RN performed an
(electrocardiogram) EKG and consulted with the provider, who
recommended the patient take acetaminophen. However, the provider did
not document a progress note in the electronic health record.
Scanning Performance
RJD staff performed satisfactorily with the scanning process. Compliance testing showed
staff often properly scanned and labeled medical files (MIT 4.004, 79.2%). OIG clinicians
identified eight deficiencies related to delayed and missing medical documents.33 The
following is an example:
• In case 23, staff scanned the infectious disease report into the electronic
health record 22 days late.
Clinician On-Site Inspection
Our clinicians discussed health information management processes with medical
leadership, the medical records supervisor, office technicians, and providers. The
supervisor reported implementing a tracking system on the spreadsheet for all off-site
medical encounters by retrieving records and reconciling them using daily movement
sheets. The technicians reported they collect documents three to four times daily from
every yard clinic and the TTA to scan and upload them into the electronic health record.
32 Deficiencies occurred in cases 2, 11, and 23.
33 Deficiencies occurred in cases 4, 6, 10, 21, 23, 24, and 26. Significant deficiencies occurred in cases 21, 23, and
26.
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Compliance Score Results
Table 8. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s electronic
20 0 15 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
29 1 15 96.7%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 16 4 5 80.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
19 5 0 79.2%
and included in the correct patients’ files? (4.004)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 21 4 0 84.0%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 88.0%
Source: The Office of the Inspector General medical inspection results.
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Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
10 0 0 100%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
6 4 0 60.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
8 1 1 88.9%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 9 1 0
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 12 2 1 85.7%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 10 4 1 71.4%
frame? (14.005)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 8 5 2 61.5%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection
control, sanitation procedures, medical supplies, equipment management, and
examination rooms. Inspectors also tested clinics’ performance in maintaining auditory
and visual privacy for clinical encounters. Compliance inspectors asked the institution’s
health care administrators to comment on their facility’s infrastructure and its ability to
support health care operations. The OIG rated this indicator solely on the compliance
score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall compliance rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (41.7%)
Overall, RJD performed poorly with respect to its health care environment. Medical
supply storage areas inside and outside the clinics contained expired medical supplies.
Emergency medical response bag (EMRB) logs were missing staff verification, missing
evidence of staff performing required inventories, or missing required medical
equipment. Furthermore, staff did not regularly sanitize their hands before and after
providing care to patients. Based on the overall compliance score result, the OIG rated
this indicator inadequate.
Compliance Testing Results
Patient Waiting Areas
We inspected only indoor waiting
areas, as RJD had no outdoor
waiting areas. Health care and
custody staff reported the existing
waiting areas contained sufficient
seating capacity (see Photo 1).
During our inspection, we did not
observe overcrowding in any of the
clinics’ indoor waiting areas.
Photo 1. Indoor patient waiting area (photographed on
8-2-23).
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Clinic Environment
Ten of 11 clinic environments were sufficiently conducive to providing medical care.
They provided reasonable auditory privacy, appropriate waiting areas, wheelchair
accessibility, and nonexamination room workspace (MIT 5.109, 90.9%). In one clinic,
however, triage stations were within close proximity to each other, which hindered
auditory privacy.
Of the 11 clinics we observed, six contained appropriate space, configuration, supplies,
and equipment to allow their clinicians to perform proper clinical examinations (MIT
5.110, 54.6%).
The remaining five clinics had one or
more of the following deficiencies:
examination rooms lacked visual
privacy; examination rooms were not
set up in a manner that provided
reasonable assurance of auditory
privacy during patient encounters;
and clinics had unsecured
confidential medical records, or
confidential medical records were
not shredded daily. One of the five
clinics had a chair with a worn cover
and a torn mat (see Photo 2).
Photo 2. Torn mat
(photographed on 8-2-23).
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Clinic Supplies
Two of the 11 clinics followed adequate
medical supply storage and management
protocols (MIT 5.107, 18.2%). We found
one or more of the following deficiencies
in the remaining nine clinics: expired
medical supplies (see Photo 3);
compromised sterile medical supply
packaging; unorganized, unidentified, or
inaccurately labeled medical supplies;
and cleaning materials stored with
medical supplies (see Photo 4, next page)
Photo 3. Expired medical supplies
(photographed on 8-23-23).
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Photo 4. Cleaning materials stored with medical supplies
(photographed on 8-17-23).
Six of the 11 clinics met requirements for essential core medical equipment and supplies
(MIT 5.108, 54.6%). The remaining five clinics lacked medical supplies or contained
improperly calibrated or nonfunctional equipment. The missing items included
examination tables with disposable paper and tips for an otoscope device. We found
nonfunctional oto-ophthalmoscopes and a weight scale that staff had not properly
calibrated. In addition, we found Snellen reading charts placed at an improper distance or
missing evidence of a clearly established distance line.
We examined EMRBs to determine whether they contained all essential items. We
checked whether staff inspected the bags daily and inventoried them monthly. Only one
of the nine applicable EMRBs passed our test (MIT 5.111, 11.1%). We found one or more
of the following deficiencies with eight EMRBs: staff failed to ensure the EMRB’s
compartments were sealed and intact; staff had not inventoried the EMRBs when the seal
tags were replaced; and EMRBs contained compromised supplies or missing items.
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Medical Supply Management
None of the medical supply storage areas
located outside the medical clinics stored
medical supplies adequately (MIT 5.106,
zero). We found expired medical supplies
in the warehouse (see Photo 5).
According to the chief executive officer
(CEO), the institution did not have any
concerns about the medical supplies
process. Health care managers and
medical warehouse managers expressed
no concerns about the medical supply
chain or their communication process.
Photo 5. Expired medical supplies in medical warehouse
(photographed 8-2-23).
Infection Control and Sanitation
Staff appropriately disinfected, cleaned,
and sanitized five of 11 clinics (MIT
5.101, 45.5%). In six clinics, we found
one or more of the following
deficiencies: staff did not maintain
cleaning logs; and medical equipment,
cabinets, clinic floors, or staff restrooms
were unsanitary (see Photo 6).
Staff in four of 11 clinics properly
sterilized or disinfected medical
equipment (MIT 5.102, 36.4%). In seven
clinics, we found one or more of the
following deficiencies: staff did not
mention disinfecting the examination
table as part of their daily start-up
protocol; staff did not use examination
table paper during an examination; and
staff did not change the examination
table paper in between patient
encounters. In one of the seven clinics,
staff did not disinfect or properly store
Photo 6. Staff restroom was unsanitary (photographed on 8-2-23).
noninvasive medical equipment (see
Photo 7, next page).
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Photo 7. Forceps were not kept in sterilized packaging
(photographed 8-1-23).
We found operating sinks and hand hygiene supplies in the examination rooms in four of
11 clinics (MIT 5.103, 36.4%). The patient restrooms in seven clinics lacked either
antiseptic soap or disposable hand towels.
We observed patient encounters in nine applicable clinics. In eight clinics, clinicians did
not wash their hands before or after physically touching their patients, before applying
gloves, or after performing a blood draw (MIT 5.104, 11.1%).
Health care staff in all clinics followed proper protocols to mitigate exposure to blood-
borne pathogens and contaminated waste (MIT 5.105, 100%).
Physical Infrastructure
We gathered information to determine whether the institution’s physical infrastructure
was maintained in a manner that supported health care management’s ability to provide
timely and adequate health care. When we interviewed health care managers, they did not
have concerns about the facility’s infrastructure or its effect on the staff’s ability to
provide adequate health care. At the time of our inspection, the institution had three
infrastructure projects underway, which management staff thought would improve the
delivery of care at RJD. These are described on the following page.
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• Project A: A medication preparation room in Facility B, Housing Unit 6,
which began in April 2023 and was expected to have been completed by
August 2023.
• Project B: A medication preparation room in Facility B, Housing Unit 7,
which began in June 2023 and was expected to have been completed by
October 2023.
• Project C: A medication distribution room in Facility C, Housing Unit 7,
which began in December 2022 and was expected to have been completed by
February 2024.
Despite the projects described above, the CEO did not believe their lack of completion
had negatively impacted the institution’s current ability to provide good patient care
(MIT 5.999).
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Cycle 7, Richard J. Donovan Correctional Facility | 43
Compliance Score Results
Table 10. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately disinfected,
5 6 0 45.5%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 4 7 0 36.4%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
4 7 0 36.4%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
1 8 2 11.1%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
11 0 0 100%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 0 1 0 0
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
2 9 0 18.2%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
6 5 0 54.6%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
10 1 0 90.9%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
6 5 0 54.6%
providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency crash
carts inspected and inventoried within required time frames, and do they 1 8 2 11.1%
contain essential items? (5.111)
Does the institution’s health care management believe that all clinical areas
This is a nonscored test. Please see the
have physical plant infrastructures that are sufficient to provide adequate
indicator for discussion of this test.
health care services? (5.999)
Overall percentage (MIT 5): 41.7%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Richard J. Donovan Correctional Facility | 44
Recommendations
• Medical leadership should determine the root cause for staff not following all
required universal hand hygiene precautions and take necessary remedial
measures.
• Nursing leadership should determine the root cause for staff not ensuring
clinic examination rooms contain essential core medical equipment. The
leadership should also verify staff follow equipment and medical supply
management protocols and should take necessary remedial measures.
• Executive leadership should determine the root cause for staff not ensuring
reusable noninvasive medical equipment is properly disinfected and take
necessary remedial measures.
• Nursing leadership should determine the root causes for staff either not
ensuring the EMRBs are regularly inventoried and sealed or not properly
completing monthly logs and should implement all necessary remedial
measures.
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Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions.
For newly arrived patients, our inspectors assessed the quality of health care screenings
and the continuity of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, inspectors checked
whether staff reviewed patient medical records and determined the patient’s need for
medical holds. They also assessed whether staff transferred patients with their medical
equipment and gave correct medications before patients left. In addition, our inspectors
evaluated staff performance in communicating vital health transfer information, such as
preexisting health conditions, pending appointments, tests, and specialty referrals.
Inspectors further confirmed whether staff sent complete medication transfer packages
to receiving institutions. For patients who returned from off-site hospitals or emergency
rooms, inspectors reviewed whether staff appropriately implemented recommended
treatment plans, administered necessary medications, and scheduled appropriate follow-
up appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (72.1%)
Case review found RJD performed well with the transfer process. When patients
transferred into and out of the institution, nurses usually performed sufficient
assessments and ensured a safe transfer process. Nurses performed satisfactorily when
patients returned from an emergency room or hospitalization; however, we found
opportunities for improvement in medication continuity for patients returning to the
institution. The OIG rated the case review component of this indicator adequate.
Compliance testing showed RJD had a mixed performance in this indicator. The
institution scored low in completing initial health screening forms. In contrast, the
institution performed very well in completing the assessment and disposition sections of
the screening process. Staff often ensured medication continuity for newly transferred
patients and ensured transfer packets for departing patients included all required
documents and medications. Based on the overall compliance score result, the OIG rated
the compliance testing component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 40 events in 25 cases in which patients transferred into or out of the
institution or returned from an off-site hospital or emergency room. We identified 18
deficiencies, three of which were significant.34
34Deficiencies occurred in cases 1, 2, 3, 9–11, 26, 31, 32, 34–36, and 67. Significant deficiencies occurred in case 2
and 32.
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Transfers In
RJD’s transfer-in process reflected a mixed performance. The compliance testing showed
problems in multiple areas of the transfer-in process. First, the timeliness of provider
appointments was intermittent for newly arrived patients and poor for preapproved
specialty consultations (MIT 1.002, 50.0% and MIT 14.010, 15.8%). Second, nurses only
occasionally provided thorough initial screenings (MIT 6.001, 32.0%). However,
compliance testing showed nurses performed excellently in completing their assessment
and disposition sections of the initial health care screening form (MIT 6.002, 95.7%). In
addition, compliance testing showed sufficient medication continuity (MIT 6.003, 77.3%).
OIG clinicians reviewed six events in four cases in which patients transferred into RJD
from other institutions. We identified three deficiencies, one of which was significant.35
Deficiencies occurred when a nurse did not consult with a provider when warranted and
when medication continuity was interrupted. This significant deficiency is explained
further in the Access to Care indicator.
Transfers Out
RJD’s transfer-out process reflected satisfactory staff performance. OIG clinicians
reviewed three transfer-out cases and found three documentation deficiencies.
Compliance testing showed patients who transferred out of the institution often
transferred with their medications (MIT 6.101, 83.3%). Case reviewers observed similar
findings.
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at high risk for
lapses in care quality. These patients typically experienced severe illness or injury. They
require more care and place a strain on the institution’s resources. In addition, because
these patients have complex medical issues, successful transfers of health information are
necessary for good quality care to continue. Any lapses in the transfer process can result
in serious consequences for these patients. Our clinicians found hospital emergency
room returns in eight cases and identified 13 deficiencies, three of which were
significant.36
RJD performed very well in providing follow-up appointments within required time
frames to patients returning from hospitalizations and emergency room encounters (MIT
1.007, 88.0%). In addition, availability and review of the community hospital records was
sufficient (MIT 4.004, 79.2% and MIT 4.005, 84.0%). However, both compliance and case
review identified poor performance in ensuring medication continuity (MIT 7.003, 28.0%).
The following is an example:
• In case 2, on two separate occasions, the patient with heart failure returned from a
community hospital, and medication continuity was interrupted. On the first occasion,
staff did not issue the newly prescribed cardiac medication. On the second occasion, staff
35 Deficiencies occurred in case 31 and 32. A significant deficiency occurred in case 32.
36 Deficiencies occurred in cases 1, 2, 3, 9–11, 23, 26, and 67. Significant deficiencies occurred in case 2 and 23.
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Cycle 7, Richard J. Donovan Correctional Facility | 47
did not issue a rescue inhaler and did not administer a dose of a chronic care cardiac
medication.
Clinician On-Site Inspection
RJD’s R&R department was staffed with an RN on each of the three shifts, excluding
weekends and holidays. Our clinicians interviewed an R&R nurse, who indicated
approximately 120 patients transferred into and out of RJD each week. We learned an
LVN would occasionally assist with obtaining vital signs and administering medications.
The R&R nurse described the process of receiving weekly notification of patients
scheduled to transfer the following week along with daily updates. In addition, the R&R
nurse indicated she often proactively reviewed the prescribed medications to anticipate
any medication-related concerns. The nurse also shared she created a spreadsheet she
used as a checklist to ensure each patient had their orders, patient education instructions,
and other documentation required for transfer.
Compliance On-Site Inspection
R&R nursing staff ensured five of six patients transferring out of the institution had the
required medications, transfer documents, and assigned durable medical equipment
(MIT 6.101, 83.3%). For one patient, the transfer packet did not have the required
medication.
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Compliance Score Results
Table 11. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Did nursing
staff complete the initial health screening and answer all screening 8 17 0 32.0%
questions within the required time frame? (6.001)
For endorsed patients received from another CDCR institution: When
required, did the RN complete the assessment and disposition section of
the initial health screening form; refer the patient to the TTA if TB signs and 22 1 2 95.7%
symptoms were present; and sign and date the form on the same day staff
completed the health screening? (6.002)
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 17 5 3 77.3%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer packet 5 1 0 83.3%
required documents? (6.101)
Overall percentage (MIT 6): 72.1%
Source: The Office of the Inspector General medical inspection results.
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Table 12. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 11 11 3 50.0%
patient seen by the clinician within the required time frame? (1.002)
Upon the patient’s discharge from the community hospital: Did the patient
receive a follow-up appointment with a primary care provider within the 22 3 0 88.0%
required time frame? (1.007)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 16 4 5 80.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 21 4 0 84.0%
review the report within five calendar days of discharge? (4.005)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient 7 18 0 28.0%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
18 7 0 72.0%
medications continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 2 8 0 20.0%
administered or delivered without interruption? (7.006)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
3 16 1 15.8%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should develop and implement internal auditing of staff
to ensure complete and thorough assessments of patients returning from
hospitalizations and should implement remedial measures as appropriate.
• Nursing leadership should identify the root causes for R&R nurses not
completing the initial health care screening, including answering all
questions and documenting an explanation for each “yes” answer; not
documenting a complete set of vital signs as part of the patient’s initial
health care screening assessment; and not completing the initial health care
screening form prior to the patient being placed in housing. Nursing
leadership should implement remedial measures as appropriate.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in
administering prescription medications on time and without interruption. The inspectors
examined this process from the time a provider prescribed medication until the nurse
administered the medication to the patient. In addition to examining medication
administration, our compliance inspectors also tested many other processes, including
medication handling, storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (51.9%)
Case review found RJD performed sufficiently in medication management. We found
most patients received their prescribed medications within acceptable time frames.
Although we identified opportunities for improvement, taking all aspects into
consideration, the OIG rated the case review component of this indicator adequate.
Compliance testing showed RJD needed to improve in this indicator. RJD had low scores
in medication continuity for patients with chronic care medications, newly prescribed
medications, and hospital discharge medications as well as patients transferring within
or temporarily housed in RJD. Conversely, the institution showed good performance in
employing general security for, and in storing medications in, its main pharmacy. Based
on the overall compliance score result, the OIG rated the compliance component of this
indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 31 cases related to medications and found 27 medication deficiencies in 12
cases, six of which were significant.37
New Medication Prescriptions
RJD needed to improve in ensuring administration and delivery of new medications
within required time frames (MIT 7.002, 64.0%). Our clinicians also found a pattern of
newly prescribed medications being administered late or not at all. The following are
examples:
• In case 2, the patient received newly prescribed blood thinners one day late
and did not receive a rescue inhaler.
• In case 21, the patient received a newly prescribed antibiotic two days late.
37 Deficiencies occurred in cases 1, 2, 3, 6, 21–23, 25, 26, 28, 32, and 65. Significant deficiencies occurred in cases
2, 21, 23, 25 and 28.
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• In case 22, the diabetic patient received a rescue medication (glucose) 10 days
late.
Chronic Medication Continuity
Compliance testing revealed most patients did not receive their chronic care medications
within required time frames (MIT 7.001, 9.5%). Analysis of compliance data showed
patients frequently received their hypertension, diabetes, thyroid, and cholesterol
medications late or not at all. In contrast, our clinicians found most patients received
their chronic care medications within acceptable time frames.
Hospital Discharge Medications
We found mixed results in medication continuity when patients returned from a
community hospital. Compliance testing showed, when patients missed medications,
nurses frequently did not document the reason. In addition, the pharmacy did not always
make medications available within required time frames. For the samples reviewed, when
rescue medications were prescribed, patients generally did not receive them timely (MIT
7.003, 28.0%). Our clinicians identified four deficiencies, three of which were significant.
One example follows:
• In case 23, when the patient returned after a hospitalization, the medication
the patient was prescribed for congestive heart failure was not available.
Specialized Medical Housing Medications
Compliance tests showed RJD performed poorly in ensuring medications were made
available and administered timely in the CTC (MIT 13.003, 20.0%). In half the
deficiencies, the patients received their medications, but the pharmacy had not made the
medication available within specified time frames. The other deficiencies occurred when
the patients received their medication one day late or not at all. In contrast, our clinicians
found only two minor deficiencies.38
Transfer Medications
RJD performed satisfactorily in ensuring patients who transferred into the institution
received their medications (MIT 6.003, 77.3%). However, we identified a need for
improvements when patients transferred from yard to yard or were temporarily housed at
the institution (MIT 7.005, 72.0% and MIT 7.006, 20.0%).
Compliance testing showed RJD performed satisfactorily in ensuring all patients who
transferred out of the institution had their needed medications (MIT 6.101, 83.3%). Our
case reviewers did not identify any medication deficiencies for patients transferring from
RJD. Additional information is discussed in the Transfers indicator.
38 Two deficiencies occurred in case 65.
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Medication Administration
RJD performed sufficiently in ensuring staff administered tuberculosis (TB) medications
(MIT 9.001, 76.5%). However, nurses needed to improve when monitoring their patients
who were prescribed TB medications (MIT 9.002, 53.3%).
OIG clinicians identified five cases in which pharmacy staff had delivered keep-on-
person (KOP) medications39 to the administration area, but nurses either did not issue the
medication or issued it late.40 We also identified two cases in which nurses documented
the patient had not requested a refill; however, either the patient had requested the
medication, or the patient was not required to request a refill because the medication was
ordered to be automatically refilled each month. An example follows:
• In case 25, the patient requested an inhaler refill. Three days later, a nurse
documented the patient was not provided with the inhaler because the
patient had not requested it.
Clinician On-Site Inspection
During the on-site inspection, OIG clinicians met with the pharmacist in charge (PIC)
and a nursing supervisor regarding specific questions identified during the clinical
reviews. The PIC provided the OIG clinicians with detailed responses. In addition, our
clinicians toured the medication administration areas and spoke with LVNs. We learned
nursing staff provided custody staff with a list of patients who had KOP medications for
pick up. Nurses also indicated pharmacy staff delivered medications to the
administration areas several times per day.
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in all applicable
clinic and medication line locations (MIT 7.101, 100%).
RJD appropriately stored and secured nonnarcotic medications in seven of 11 clinic and
medication line locations (MIT 7.102, 63.6%). In four of the clinic locations, we observed
one or more of the following deficiencies: the medication storage location was
disorganized or unsanitary; the medication area lacked a clearly labeled, designated area
for medications to be returned to the pharmacy; nurses did not maintain unissued
medication in its original labeled packaging; and medications were not properly secured
as required by CCHCS policy.
Staff kept medications protected from physical, chemical, and temperature
contamination in three of the 11 clinic and medication line locations (MIT 7.103, 27.3%).
In seven locations, we observed one or both of the following deficiencies: staff did not
store internal and external medications separately, and the medication refrigerator was
unsanitary. In one location, staff did not maintain a temperature log for medications
stored in the examination room.
39 Keep on person refers to medications a patient can keep and self-administer according to the directions
provided.
40 KOP medications not administered by nursing timely or not at all occurred in cases 1, 2, 21, 21, 26, and 28.
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Staff successfully stored valid, unexpired medications in 10 of the 11 applicable
medication line locations (MIT 7.104, 90.9%). In one location, nurses did not label the
multiple-use medication as per CCHCS policy.
Nurses exercised proper hand hygiene and contamination control protocols in two of
seven applicable locations (MIT 7.105, 28.6%). In five locations, some nurses neglected to
wash or sanitize their hands before each subsequent regloving.
Staff in six of seven applicable medication preparation and administration areas showed
appropriate administrative controls and protocols (MIT 7.106, 85.7%). In one location,
medication nurses could not describe the process they followed when reconciling newly
received medication and the medication administration record (MAR) against the
corresponding physician’s order.
Staff in three of seven applicable medication areas used appropriate administrative
controls and protocols when distributing medications to their patients (MIT 7.107,
42.9%). In four clinics, we observed one or more of the following deficiencies: medication
nurses did not distribute medications to patients within the required time frame;
medication nurses did not reliably observe patients while they swallowed direct
observation therapy medications; and nurses did not properly follow insulin protocols.
Pharmacy Protocols
RJD followed general security, organization, and cleanliness management protocols in its
main and remote pharmacies (MIT 7.108, 100%). In its remote pharmacy, RJD properly
stored nonrefrigerated medication. However, in its main pharmacy, we found
compromised medication packaging (MIT 7.109, 50.0%). The institution did not properly
store refrigerated or frozen medications in pharmacy locations. In both locations, we
found unsanitary medication refrigerators (MIT 7.110, zero). The PIC correctly accounted
for narcotic medications stored in RJD’s pharmacies (MIT 7.111, 100%).
We examined 18 medication error reports. The PIC had no evidence a pharmacy error
follow-up review was performed for any of the medication errors (MIT 7.112, zero).
Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors
also follow up on any significant medication errors found during compliance testing. We
did not score this test; we provide these results for informational purposes only. At RJD,
the OIG did not find any applicable medication errors (MIT 7.998).
The OIG interviewed patients in restricted housing units to determine whether they had
immediate access to their prescribed asthma rescue inhalers or nitroglycerin
medications. Fifteen of the 20 applicable patients we interviewed indicated they had
access to their rescue medications. Five patients reported they did not have their
prescribed rescue inhaler. One patient stated he did not possess his rescue inhaler during
transfer to the restricted housing unit, while the remaining patients reported their
medications were placed with their property when they were transferred to the restricted
housing unit. We promptly notified the CEO of these concerns, and health care
management immediately issued a replacement rescue inhaler to each applicable patient
(MIT 7.999).
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Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
2 19 4 9.5%
or did the institution follow departmental policy for refusals or no‑shows? (7.001)
Did health care staff administer, make available, or deliver new order prescription
16 9 0 64.0%
medications to the patient within the required time frames? (7.002)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 7 18 0 28.0%
required time frames? (7.003)
For patients received from a county jail: Were all medications ordered by the
institution’s reception center provider administered, made available, or delivered to N/A N/A N/A N/A
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
18 7 0 72.0%
continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily housed
patient had an existing medication order, were medications administered or 2 8 0 20.0%
delivered without interruption? (7.006)
All clinical and medication line storage areas for narcotic medications: Does the
institution employ strong medication security controls over narcotic medications 10 0 1 100%
assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution properly secure and store nonnarcotic medications in the assigned 7 4 0 63.6%
storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution keep nonnarcotic medication storage locations free of contamination in 3 8 0 27.3%
the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution safely store nonnarcotic medications that have yet to expire in the 10 1 0 90.9%
assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ and
follow hand hygiene contamination control protocols during medication 2 5 4 28.6%
preparation and medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 6 1 4 85.7%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 3 4 4 42.9%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization,
2 0 0 100%
and cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
1 1 0 50.0%
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
0 2 0 0
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
2 0 0 100%
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting protocols?
0 18 0 0
(7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the OIG This is a nonscored test. Please see the indicator
find that medication errors were properly identified and reported by the institution?
(7.998) for discussion of this test.
Pharmacy: For Information Purposes Only: Do patients in restricted housing units This is a nonscored test. Please see the indicator
have immediate access to their KOP prescribed rescue inhalers and nitroglycerin
medications? (7.999) for discussion of this test.
Overall percentage (MIT 7): 51.9%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: If the
patient had an existing medication order upon arrival, were medications 17 5 3 77.3%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer- 5 1 0 83.3%
packet required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
13 4 0 76.5%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 8 7 2 53.3%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 2 8 0 20.0%
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical and nursing leadership should ensure chronic care, hospital
discharge, and en route patients receive their medications timely and without
interruption; leadership should implement remedial measures as appropriate.
• The institution should consider developing and implementing measures to
ensure staff timely make available and administer medications to patients as
described in CCHCS policy and procedures.
• Nursing leadership should consider developing and implementing measures
to ensure nursing staff document patients’ refusal reasons and no-shows on
MAR summaries, in accordance with CCHCS’ policies and procedures.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
out patients quickly. The OIG rated this indicator solely according to the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (69.6%)
RJD had a mixed performance in preventive services. Staff performed perfectly in offering
influenza vaccines for the most recent influenza season and in screening patients
annually for TB. The institution showed very good performance in screening patients
from the ages of 45 through 75 for colorectal cancer and in administering TB
medications. However, RJD performed poorly in monitoring patients taking prescribed
TB medications or in offering required immunizations to chronic care patients. Based on
the overall compliance score result, the OIG rated this indicator inadequate.
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Compliance Score Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
13 4 0 76.5%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 8 7 2 53.3%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
25 0 0 100%
(9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
22 3 0 88.0%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients? (9.008) 0 12 13 0
Are patients at the highest risk of coccidioidomycosis (Valley Fever)
N/A N/A N/A N/A
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 69.6%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should consider developing and implementing measures
to ensure nursing staff consistently perform patient monitoring as described
in CCHCS care guides, and nursing staff completely address TB signs and
symptoms in their patient monitoring.
• Medical leadership should determine the root cause of challenges in the
timely provisions of vaccinations to chronic care patients and implement
remedial measures as appropriate.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care delivered by the
institution’s nurses, including registered nurses (RN), licensed vocational nurses (LVN),
psychiatric technicians (PT), certified nursing assistants (CNA), and medical assistants
(MA). Our clinicians evaluated nurses’ performance in making timely and appropriate
assessments and interventions. We also evaluated the institution’s nurses’ documentation
for accuracy and thoroughness. Clinicians reviewed nursing performance across many
clinical settings and processes, including sick call, outpatient care, care coordination and
management, emergency services, specialized medical housing, hospitalizations,
transfers, specialty services, and medication management. The OIG assessed nursing care
through case review only and performed no compliance testing for this indicator.
When summarizing nursing performance, our clinicians understand nurses perform
numerous aspects of medical care. As such, specific nursing quality issues are discussed
in other indicators, such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
In Cycle 7, the RJD’s nursing performance declined. Compared with Cycle 6, RJD nurses
had more total deficiencies and more significant deficiencies. Our clinicians identified
opportunities for improvement in several areas of the nursing process described in the
areas below. The amount of significant assessment-related deficiencies could place
patients at risk of harm. In addition, RJD’s nursing leadership did not identify
opportunities for improvement and did not have sufficient mechanisms in place to
monitor the quality of nurses’ clinical performance. The OIG rated this indicator
inadequate.
Case Review Results
We reviewed 279 nursing encounters in 66 cases. Of the nursing encounters we reviewed,
134 occurred in the outpatient setting, and 69 were sick call requests. We identified 147
nursing performance deficiencies, 26 of which were significant.41
Outpatient Nursing Assessment and Interventions
Our clinicians identified 82 outpatient nursing deficiencies, 13 of which were significant.
Of the 82 deficiencies, 44 related to incomplete nursing assessments. These deficiencies
occurred when nurses in the outpatient areas did not arrange a same-day nurse
41 Deficiencies occurred in cases 1–8, 10, 11, 14, 16–18, 20, 21, 23–26, 29, 31, 34–36, 38–44, 46-50, 52–58, 61, 62, 64,
66, and 67. Significant deficiencies occurred in cases 2, 4, 6, 10, 11, 16, 21, 23, 24, 26, 29, 46, 48, 61, 65, and 66.
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appointment and did not provide sufficient assessments or care plans. Examples are
listed in the following cases:
• In case 16, an LVN documented the patient’s finger-stick blood glucose
result was critically low. However, the LVN did not inquire whether the
patient had other signs or symptoms of hypoglycemia and did not consult
with an RN or provider about the abnormal result.
• In case 21, the diabetic patient submitted a sick call request for a wheelchair
cushion. During the sick call appointment, the patient complained of buttock
and leg wounds; however, the nurse did not assess the wounds. In addition,
in cases 1, 24, and 58, nurses did not thoroughly assess these diabetic
patients’ wounds.
• In case 24, the diabetic patient complained to an LVN about a new wound.
Instead of arranging an RN or provider evaluation, the LVN advised the
patient to submit a sick call request. The patient did submit a sick call
request and also complained of calf swelling.42 However, the RN conducting
triage did not arrange for a same-day evaluation. When an RN evaluated this
patient, the nurse did not perform a sufficient assessment, did not consult
with a provider, and did not schedule a follow-up appointment. In addition,
in cases 11, 26, and 48, nurses did not arrange same-day assessments of
potentially urgent symptoms.
• In case 61, the patient complained of rectal bleeding and constipation. The
nurse documented the patient’s abdomen was asymmetric but did not consult
with a provider regarding this abnormal finding. In addition, the nurse did
not subjectively assess the onset, frequency, and characteristics of the
patient’s rectal bleeding.
Outpatient Nursing Documentation
Complete and accurate nursing documentation is an essential component of patient care.
Without proper documentation, health care staff can overlook changes in patient
conditions. On multiple occasions, nurses inconsistently documented or did not
thoroughly document their assessment findings. The following are examples:
• In case 18, the patient had a rash; however, the nurse did not document the
rash’s appearance.
• In case 42, the patient experienced a hand injury. In the same assessment, the
nurse documented the injured hand had both limited and full range of
motion, which was contradictory.
Emergency Services
We reviewed 47 urgent or emergent events and identified 30 nursing deficiencies, eight of
which were significant. Although nurses usually responded promptly to emergent events,
we found a pattern of incomplete initial assessments. In addition, nursing assessments,
42 Calf swelling is a symptom associated with a blood clot and warrants a same-day assessment.
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interventions, and documentations showed room for improvement, which we detailed
further in the Emergency Services indicator.
Hospital Returns
We reviewed 30 events that involved returns from off-site hospitals or emergency rooms.
We identified four nursing deficiencies. Three related to incomplete assessment,
intervention, and documentation. Otherwise, nurses performed good nursing
assessments. Please refer to the Transfers indicator for additional details.
Transfers
Our clinicians reviewed seven cases involving transfer-in and transfer-out processes, and
we identified four nursing deficiencies. Compliance testing showed nurses only
occasionally provided timely initial screenings but performed well when completing the
assessment and disposition portions of the initial health screening form. We found
nurses did not always document pertinent information when patients transferred out of
the institution. Please refer to the Transfers indicator for additional details.
Specialized Medical Housing
We reviewed four cases with a total of 41 nursing events and identified 28 nursing
deficiencies, four of which were significant. These deficiencies related to both
incomplete initial nursing assessments and nurses’ failures to follow a provider’s orders
for activities of daily living and external feedings. An example is detailed below:
• In case 65, a provider ordered the patient to be placed in a wheelchair twice
during the day and repositioned in bed every two hours, but nurses did not
consistently follow these orders. In addition, nurses did not administer the
tube feeding amounts as prescribed.
For more specific details, please refer to the Specialized Medical Housing indicator.
Specialty Services
We reviewed 27 events in which nurses evaluated patients after an off-site specialty
procedure or consultation. We identified five nursing deficiencies related to specialty
services, one of which was significant. Please refer to the Specialty Services indicator for
additional details.
Medication Management
OIG clinicians examined 166 events involving medication management. Our clinicians
found a pattern of nurses not issuing KOP medications within necessary time frames. An
example is listed below:
• In case 1, pharmacy staff delivered the patient’s KOP diabetes medication
timely to the medication distribution area; however, nursing staff issued the
medication 14 days later.
Please refer to the Medication Management indicator for additional details.
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Clinician On-Site Inspection
Our clinicians spoke with nurses in the TTA, CTC, R&R, specialty services, outpatient
clinics, and medication areas. We attended well-organized morning huddles and a
medical subcommittee meeting. We found medical staff knowledgeable and familiar with
their patient population. Our clinicians were impressed by the subcommittee meeting
presentation and staff involvement; the subcommittee established deadlines, updates and
discussions occurred, and subcommittee members reviewed tracking and trending of
goals.
The CNE, who started her position with RJD in 2017, stated she had knowledgeable
supervisors, and staff advocated for their patients. The CNE described challenges related
to staffing allocation not correlating with the volume and complicated health conditions
of RJD’s patients. The CNE also disclosed psychiatric technician positions were difficult
to fill, with the institution experiencing a 40 percent vacancy rate. In addition, in other
areas with limited staff, nursing leadership reported using creative scheduling or
overtime to meet staffing needs.
During our inspection, we spoke to nursing staff who informed us of their low morale.
The CNE acknowledged this challenge and indicated the nurses had expressed their
feelings of being overworked and of feeling “burnt out,” both related to the high volume
of patient encounters and low staffing ratios. However, the CNE indicated the leadership
team was working on team building efforts and hoped morale would improve.
Our clinicians further inquired about how nursing leadership assessed the quality of care
RJD’s nursing staff provided. The CNE reported her nursing leadership conducted annual
evaluations, performed audits, and monitored logs. This included auditing random sick
calls, reviewing controlled medication mismatch reports, reviewing dashboards,
participating in quality management meetings, reviewing health care incident reports,
completing emergency clinical reviews, conducting R&R audits, and facilitating urgent
and emergent care discussions. While these reviews and audits could be helpful in
monitoring compliance with individual health care requirements, the OIG found many of
the audits did not assess the quality of nurses’ clinical performance.
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Recommendations
• Nursing leadership should determine the challenges to ensuring nursing
staff complete thorough assessments, provide appropriate interventions, and
thoroughly document encounters. Leadership should implement remedial
measures as appropriate.
• Nursing leadership should develop and implement measures to assess the
clinical quality of nursing care, in addition to the current compliance audits,
and should provide training and education as necessary.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of care delivered by the
institution’s providers: physicians, physician assistants, and nurse practitioners. Our
clinicians assessed the institution’s providers’ performance in evaluating, diagnosing,
and managing their patients properly. We examined provider performance across several
clinical settings and programs, including sick call, emergency services, outpatient care,
chronic care, specialty services, intake, transfers, hospitalizations, and specialized
medical housing. We assessed provider care through case review only and performed no
compliance testing for this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
RJD providers delivered acceptable medical care. Providers generally evaluated patients
appropriately, diagnosed medical conditions correctly, and managed chronic conditions
effectively. They appropriately referred patients to specialists and for a higher level of
care when needed. However, we found opportunities for improvement for providers in
performing pertinent physical examinations during evaluations and documenting
progress notes when providing co-consultations with nursing staff. After careful
consideration of all these factors, the OIG rated this indicator adequate.
Case Review Results
OIG clinicians reviewed 175 medical provider encounters and identified 58 deficiencies,
13 of which were significant.43 In addition, our clinicians examined the quality of care in
25 comprehensive case reviews. Of these 25 cases, we found 21 adequate and four
inadequate.
Outpatient Assessment and Decision-Making
Providers generally made appropriate assessments and sound medical decisions for their
patients. Most of the time, providers diagnosed medical conditions correctly, ordered
appropriate tests, and referred their patients to specialists when needed. However, our
clinicians identified 39 deficiencies related to poor medical assessments and decision-
making, nine of which were significant.44 The following are examples:
• In case 3, the provider evaluated the patient for surgical clearance
prior to undergoing total knee replacement. During the evaluation,
the provider did not perform a comprehensive review of systems and
symptoms, obtain vital signs, or perform a cardiopulmonary
43 Deficiencies occurred in cases 2, 3, 10–14, 16, 17, 20–24, and 26–30. Significant deficiencies occurred in cases
3, 12, 16, 26, 28 and 29.
44 Deficiencies occurred in cases 3, 10, 12-14, 17, 21, 24, and 26–30. Significant deficiencies occurred in cases 3,
12, 26, 28, and 29.
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examination for this patient, who had cardiac and pulmonary
disease. Furthermore, the provider did not review the MAR to either
evaluate the current medication status or address the patient’s
frequent refusal of insulin.
• In case 26, the provider evaluated the patient for follow up after the
CT scan of the brain showed evidence of ischemia.45 The provider did
not complete a full neurologic review of systems and did not perform
a comprehensive neurologic examination during the encounter.
Review of Records
Providers generally performed well in reviewing medical records and addressing
hospitalists’ recommendations for patients returning from hospitalizations. However, we
identified four deficiencies.46 The following is an example:
• In case 26, at a follow-up appointment, the provider evaluated the patient
with a history of stroke and speech difficulties. Although the patient had
received a Holter monitor test two months prior to the appointment, the
provider did not discuss the results of 24-hour Holter monitoring to assess
for a possible embolic cause of the stroke as recommended by the
neurologist.47
Emergency Care
Providers usually managed patients in the TTA with urgent or emergent conditions
appropriately. In addition, providers were available for consultation with TTA staff. We
identified three deficiencies related to emergency care, none of which were significant .48
We also discuss these deficiencies in the Emergency Services indicator.
Chronic Care
In most instances, providers appropriately managed patients’ chronic health conditions,
such as hypertension, diabetes, asthma, hepatitis C infection, and cardiovascular disease.
However, we identified one significant deficiency related to the management of diabetes
as discussed in the following example:
• In case 16, the provider evaluated the patient at a follow-up appointment
after an off-site return and for chronic care. However, the provider did not
adequately assess the patient’s diabetes in reviewing the fluctuating glucose
finger-stick readings, which the provider should have done as the patient was
receiving frequent steroids for cancer treatment. Furthermore, the provider
did not address the patient’s other chronic care conditions including
45 Ischemia means reduced blood flow to any tissue or organ of the body, resulting in insufficient blood supply.
46 Deficiencies occurred in cases 3, 13, 20, and 26.
47 An embolic cause of a stroke occurs when a blood clot from another part of the body travels through the
bloodstream to the brain. The clot blocks the blood flow, resulting in a stroke.
48 Deficiencies occurred in cases 1 and 15–17.
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hypertension, hyperlipidemia, hepatitis C infection, and history of deep vein
thrombosis during this encounter.
Specialty Services
Providers appropriately referred patients for specialty consultation when needed. When
specialists made recommendations, providers usually followed the recommendations
appropriately and reviewed specialty reports timely. We identified one deficiency for not
thoroughly reviewing the specialty report, one for not timely referring the patient to the
specialist, and two for not fully following specialists’ recommendations. Only one was
significant.49 The following are examples:
• In case 16, the patient returned from an off-site chemotherapy appointment
with instructions to return in one week. However, the provider did not
thoroughly review the specialist’s recommendations. Consequently, the
chemotherapy appointment was delayed for the patient.
• In case 26, the provider evaluated the patient following a neurology
consultation for stroke. The neurologist recommended the patient be
referred to a cardiologist and receive an MRA as soon as possible.50 However,
the provider did not complete these referrals.
We discuss providers’ specialty performance further in the Specialty Services indicator.
Documentation Quality
Providers generally documented outpatient encounters on the same day of the encounter.
However, we identified one significant deficiency in not completing a progress note and
five deficiencies with delays in completing progress notes.51 The following are examples:
• In case 3, the provider evaluated the patient for a follow-up appointment
after return from a higher level of care and abnormal laboratory results at a
chronic care appointment. However, the provider did not document a
progress note for the encounter including the rationale for medication
changes and new laboratory orders.
• In case 16, the provider evaluated the patient in the clinic. However, the
provider did not complete the progress note until six days later.
Documentation is important because it shows the provider’s thought process during
clinical decision-making. When contacted by nurses, providers did not always document
those interactions. Our clinicians found five such undocumented interactions.52 The
following is an example:
• In case 26, a nursing staff co-consulted with the provider concerning this
patient with an abscess and swelling of the left forearm. The provider
49 Deficiencies occurred in case 16, 23, 16, and 27. A significant deficiency occurred in case 26.
50 An MRA is a magnetic resonance angiography scan used to image the blood vessels in the body.
51 Deficiencies occurred in case 16.
52 Deficiencies occurred in cases 26, 27, and 28.
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ordered antibiotics for the patient but did not document a progress note in
the electronic health record.
Provider Continuity
RJD offered good provider continuity. Providers were assigned to specific clinics and
took care of their assigned patients.
Clinician On-Site Inspection
OIG clinicians observed morning huddles and provider meetings, including the medical
subcommittee meeting, which were well attended.
We discussed the expectations for medical provider documentation with medical
leadership. The leadership reported, before the clinician on-site inspection, RJD provided
updates on HCDOM 1.4.22, “Medical Provider Documentation Expectations,” and a new
RJD LOP, “RJD Medical Provider Documentation Expectations.” Leadership reported the
goals were to establish clear expectations for the staff to follow.
Medical leadership reported implementing a diabetes care manager (CM) program to
improve in chronic care management. Under this program, designated nursing staff
provided diabetes care by collaborating with clinic providers and patients to directly
monitor glucose levels and medication compliance.
The OIG physician met with the CME, the chief physician and surgeon (CP&S), and
individual clinic providers. Providers expressed medical leadership supported them well.
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Recommendations
• Medical leadership should develop and implement monitoring strategies to
ensure providers follow medical provider documentation expectations
according to the department’s HCDOM and RJD LOP.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing,
monitoring, and intervening for medically complex patients requiring close medical
supervision. Our inspectors also evaluated the timeliness and quality of provider and
nursing intake assessments and care plans. We assessed staff members’ performance in
responding promptly when patients’ conditions deteriorated and looked for good
communication when staff consulted with one another while providing continuity of
care. At the time of our inspection, RJD’s specialized medical housing consisted of a
correctional treatment center (CTC).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (70.0%)
Case review found RJD performed satisfactorily in this indicator. We found providers
evaluated their patients appropriately. Although nurses showed opportunities to improve
their assessments, interventions, and documentation, the OIG rated the case review
component of this indicator adequate.
Compared with Cycle 6, compliance testing showed RJD needed to improve in this
indicator. Providers performed well in completing history and physical examinations
within required time frames. However, nursing staff needed to improve in timely
completing initial assessments and in ensuring medication continuity for patients newly
admitted to the specialized medical housing unit. Based on the overall compliance score
result, the OIG rated the compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed five CTC cases that included 32 provider events and 41 nursing events. Due
to the frequency of nursing and provider contacts in the specialized medical housing, we
may bundle up to two weeks of patient care into a single event. We identified 33
deficiencies, five of which were significant.53
Provider Performance
Case review clinicians evaluated five patients admitted to RJD’s specialized medical
housing unit and found no deficiencies. Compliance testing showed providers generally
completed timely admission health and physical examinations (MIT 13.002, 90.0%).
Providers completed their rounds at clinically appropriate intervals, developed good care
plans, made sound medical decisions, and documented well.
53 Deficiencies occurred in cases 1, 2, 23, and 65–67. Significant deficiencies occurred in cases 2, 65, and 66.
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Nursing Performance
Compliance testing showed nurses needed to improve in completing timely admission
assessments (MIT 13.001, 70.0%). In contrast, case review evaluated five nurse admissions
and did not identify deficiencies in the timeliness of these admission assessments.
However, in two cases, we found assessments were incomplete.54 In addition, case review
found opportunities for improvement in nurses’ assessments, interventions, and
documentation. The following are examples:
• In case 2, a CTC nurse performed an incomplete admission assessment. The
nurse did not assess the patient’s surgical site and did not perform a pain
assessment despite the patient’s complaint of pain.
• In case 65, the patient frequently complained of pain around the feeding tube
site, but the nurses documented the patient did not have any pain. In
addition, on a few occasions, nurses found a change in the patient’s
condition, but did not notify a provider.
• In case 66, this patient with esophageal cancer had multiple wounds;
however, the labeling of the wound locations was inconsistent. In addition,
nurses frequently documented administering enteral feeding amounts
inconsistent with providers’ orders.55
Medication Administration
Compliance testing revealed patients admitted to the CTC rarely received their
medications timely (MIT 13.003, 20.0%). In contrast, our clinicians identified two
deficiencies related to medication management.56 We discuss these in the Medication
Management indicator.
Clinician On-Site Inspection
The CTC had 14 medical beds, two of which were negative pressure rooms for respiratory
isolation. At the time of our inspection, the CTC had two vacant rooms.
Nurses staffed the CTC 24 hours per day, and staffing included RNs, LVNs, and CNAs. In
the CTC, staff completed grand rounds each week and conducted weekly meetings to
review care plans for each patient.57 The provider, the RN, the utilization management
(UM) RN, and a mental health clinician attended these weekly meetings. Nursing staff
reported they felt supported by nursing administration.
54 Incomplete nursing assessments occurred in case 2 and 66.
55 Enteral feedings are used as a means to provide patient nutrient needs. Enteral feedings can include feeding
tubes through the mouth, nose, or stomach.
56 Deficiencies occurred in case 65.
57 Grand rounds involve a multidisciplinary team approach that includes providers, nurses, and a care team, who
gather to discuss the patient’s plan of care.
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During normal business hours, excluding weekends and holidays, providers were
available on site. CTC nurses contacted the on-call provider, who generally had a laptop
computer to access the patient’s medical record.
At the time of our on-site inspection, the supervising registered nurse (SRN) had been
acting in the position for two months. The SRN reported using compliance auditing tools
to measure the quality of nursing performance in the CTC.
Compliance On-Site Inspection
At the time of the compliance on-site inspection, the CTC had a functional call light
communication system (MIT 13.101, 100%).
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Compliance Score Results
Table 16. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Did the registered nurse complete an initial
7 3 0 70.0%
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
9 1 0 90.0%
required time frame? (13.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 2 8 0 20.0%
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call 1 0 0 100%
system? (13.101)
For specialized health care housing (CTC, SNF, hospice, OHU): Do health
care staff perform patient safety checks according to institution’s local 0 0 1 N/A
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): 70.0%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should determine the challenges to ensuring nursing
staff complete thorough documentation of wound care assessments,
including clinical appearance of the wound, surrounding tissue, and
measurements. Leadership should implement remedial measures as
appropriate.
• Nursing leadership should ensure nursing staff completes initial assessments
within the time frame required by CCHCS policy.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. OIG
clinicians focused on the institution’s performance in providing needed specialty care.
Our clinicians also examined specialty appointment scheduling, providers’ specialty
referrals, and medical staff’s retrieval, review, and implementation of any specialty
recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (67.7%)
Case review found RJD generally provided satisfactory specialty services for patients.
Providers often appropriately referred to specialists and followed up after the specialty
consultations. TTA nurses performed well in assessing patients after returning from
specialty appointments. However, we found opportunities for improvement in providers
reviewing and endorsing specialists’ reports following specialist recommendations, and
in staff retrieving and scanning the reports within required time frames. The OIG rated
the case review component of this indicator adequate.
Compliance testing showed RJD needs improvement in this indicator. RJD scored low in
providing high-, medium-, and routine-priority specialty services. Staff needs
improvement in providing preapproved specialty services for patients newly transferred
into RJD as well as in endorsing and reviewing specialty reports. Based on the overall
compliance score result, the OIG rated the compliance component of this indicator
inadequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 196 events related to specialty services, which included 154
specialty consultations and procedures, 15 on-site specialty services, and 27 nursing
encounters. We identified 33 deficiencies in this category, eight of which were
significant.58
Access to Specialty Services
Compliance testing showed patients sometimes received high-priority specialty referrals
(MIT 14.001, 60.0%) and sporadically received continuity of specialty services upon
transfer into the institution (MIT 14.010, 15.8%). In addition, patients intermittently
received medium- and routine-priority specialty referrals within the required time frames
(MIT 14.004, 73.3% and MIT 14.007, 73.3%). OIG clinicians identified six deficiencies
58 Deficiencies occurred in cases 2, 12, 14, 17, 20, 22–24, 26, 27–29, and 67. Significant deficiencies occurred in
cases 23, 26, 28, and 29.
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related to specialty appointments, two of which were significant.59 The following is an
example:
• In case 26, the provider requested an urgent specialty referral for an MRI of
the brain. The study was completed six days after the requested date.
Provider Performance
In general, providers appropriately referred patients and usually followed the specialists’
recommendations. Compliance testing showed follow-up appointments with providers
after specialty consultations often occurred within required time frames (MIT 1.008,
78.1%). OIG clinicians identified 13 deficiencies in which providers did not endorse
specialists’ reports timely, three of which were significant.60 The following is an example:
• In case 26, staff scanned the patient’s report for a 24-hour Holter monitor
heart test into the electronic health record over two months after it was
performed. Furthermore, the provider endorsed the report 19 calendar days
after the report became available.
Nursing Performance
The specialty nurses reviewed specialty service requests and appropriately scheduled
patients for specialty appointments. TTA nurses properly assessed patients after
returning from off-site specialty appointments, reviewed specialists’ recommendations,
and communicated them to providers. OIG clinicians reviewed 27 nursing encounters
related to specialty services and only identified one significant deficiency. The following
is an example:
• In case 29, the neurosurgeon evaluated the patient with a high-priority
referral. However, the specialty nurse did not provide the diagnostic MRI
scan images to the specialist for evaluation. This delayed the neurosurgical
interventional care for this patient, who had chronic cauda equina syndrome
with severe spinal stenosis.61
This is discussed further in the Nursing Performance indicator.
Health Information Management
While providers mostly received and reviewed high-priority specialty reports within
required time frames, they intermittently reviewed medium- and routine-priority
specialty reports within required time frames (MIT 14.002, 85.7%, MIT 14.005, 71.4%, and
MIT 14.008, 61.5%). Staff nearly always scanned specialty reports into the electronic
health record within the required time frame (MIT 4.002, 96.7%). OIG clinicians
identified one significant deficiency related to delays in retrieving and scanning the
59 Deficiencies occurred in cases 23, 26, 28, and 29. A significant deficiency occurred in case 29.
60 Delayed endorsement deficiencies occurred in cases 12, 20, 22, 24, and 26–29. Significant deficiencies
occurred in cases 26 and 29.
61 Spinal stenosis is a medical condition in which the spinal column narrows and compresses on the spinal cord.
This may cause pain and disability. Cauda equina syndrome is a condition in which the nerves below the end of
the spinal cord are damaged, resulting in effects on nerve function such as a loss of bladder and bowel control.
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report, one deficiency related to not obtaining the report, and two deficiencies related to
sending patient notification letters with results of specialty procedures.62 The following
are examples:
• In case 23, staff scanned the infectious disease specialist report 22 days late.
• In case 26, the nursing staff assessed the patient after an off-site speech
therapy evaluation. The nurses documented the therapist’s report was not
available but did not attempt to obtain these records.
Clinician On-Site Inspection
We discussed specialty referral management with medical and nursing leadership,
providers, specialty nurses, and the utilization management nurse. Nursing staff reported
they review specialty requests, contact specialists for available appointments, and
schedule the appointments. However, they reported challenges with staffing due to an
increased number of off-site, on-site, and telemedicine referral requests. RJD offered on-
site specialty services including audiology, ophthalmology, optometry, physical therapy,
podiatry, and renal replacement therapy (hemodialysis services). Medical leadership
reported obtaining space for an on-site coumadin clinic for anticoagulation therapy by a
clinical pharmacist.
62 Deficiencies occurred in cases 14, 23, and 26.
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Compliance Score Results
Table 17. Specialized Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within 14 calendar
days of the primary care provider order or the Physician Request for 9 6 0 60.0%
Service? (14.001)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 12 2 1 85.7%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 4 3 8 57.1%
(14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or Physician Request for 11 4 0 73.3%
Service? (14.004)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 10 4 1 71.4%
frame? (14.005)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 8 5 2 61.5%
(14.006)
Did the patient receive the routine-priority specialty service within 90
calendar days of the primary care provider order or Physician Request for 11 4 0 73.3%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 8 5 2 61.5%
frame? (14.008)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 9 0 6 100%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
3 16 1 15.8%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Did the institution deny the primary care provider’s request for specialty
19 1 0 95.0%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
11 8 1 57.9%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 67.7%
Source: The Office of the Inspector General medical inspection results.
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Table 18. Other Tests Related to Specialized Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up visits
32 9 4 78.1%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
29 1 15 96.7%
within five calendar days of the encounter date? (4.002)
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the root causes of challenges to the
timely provision of specialty services with high-priority referrals as well as
their subsequent high-priority specialty follow-up appointments and should
implement remedial measures as appropriate.
• The department should consider developing and implementing measures to
ensure institutions timely receive the medium- and routine-priority specialty
reports, and providers timely review these reports.
• Medical leadership should identify the root cause of challenges to the timely
provision of preapproved specialty appointments for transfer-in patients and
should implement remedial measures as appropriate.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care administrative
processes. Our inspectors examined the timeliness of the medical grievance process and
checked whether the institution followed reporting requirements for adverse or sentinel
events and patient deaths. Inspectors checked whether the Emergency Medical Response
Review Committee (EMRRC) met and reviewed incident packages. We investigated and
determined whether the institution conducted required emergency response drills.
Inspectors also assessed whether the Quality Management Committee (QMC) met
regularly and addressed program performance adequately. In addition, our inspectors
determined whether the institution provided training and job performance reviews for its
employees. We checked whether staff possessed current, valid professional licenses,
certifications, and credentials. The OIG rated this indicator solely based on the
compliance score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall compliance rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (61.2%)
RJD’s performance was mixed in this indicator. While RJD scored well in some applicable
tests, it needed improvement in several areas. The Emergency Medical Response Review
Committee (EMRRC) did not complete the required checklists and review the cases
within required time frames. Meeting minutes from the local governing body were either
missing the preinspection documents or missing approval documentation. In addition,
the institution did not conduct live medical emergency response drills. Physician
managers only occasionally completed annual performance appraisals in a timely
manner. Lastly, the nurse educator did not ensure newly hired nurses received the
required onboarding training timely. These findings are set forth in the table on the next
page. Based on the overall compliance score result, the OIG rated this indicator
inadequate.
Compliance Testing Results
Nonscored Results
At RJD, the OIG did not have any applicable adverse sentinel events requiring root cause
analysis during our inspection period (MIT 15.001).
We obtained CCHCS Mortality Case Review reporting data. In our inspection, for six
patients, we found no evidence in the submitted documentation the preliminary mortality
reports had been completed. These reports were overdue at the time of the OIG’s
inspection. The remaining four reports were beyond the inspection review period and
were exempted (MIT 15.998).
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Compliance Score Results
Table 19. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the This is a nonscored test. Please refer to the
institution meet RCA reporting requirements? (15.001) discussion in this indicator.
Did the institution’s Quality Management Committee (QMC) meet monthly?
6 0 0 100%
(15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
0 4 8 0
packages the committee reviewed include the required documents?
(15.003)
For institutions with licensed care facilities: Did the Local Governing Body
(LGB) or its equivalent meet quarterly and discuss local operating 0 4 0 0
procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during each
watch of the most recent quarter, and did health care and custody staff 0 3 0 0
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
8 2 0 80.0%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
8 2 0 80.0%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
5 9 0 35.7%
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 19 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 6 0 1 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 2 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
0 1 0 0
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG medical This is a nonscored test. Please refer to Table 3
inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 61.2%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to review
CCHCS policies and procedures, relevant court orders, and guidance developed by the
American Correctional Association. We also reviewed professional literature on
correctional medical care; reviewed standardized performance measures used by the
health care industry; consulted with clinical experts; and met with stakeholders from the
court, the receiver’s office, the department, the Office of the Attorney General, and the
Prison Law Office to discuss the nature and scope of our inspection program. With input
from these stakeholders, the OIG developed a medical inspection program that evaluates
the delivery of medical care by combining clinical case reviews of patient files, objective
tests of compliance with policies and procedures, and an analysis of outcomes for certain
population-based metrics.
We rate each of the quality indicators applicable to the institution under inspection based
on case reviews conducted by our clinicians or compliance tests conducted by our
registered nurses. Figure A–1 below depicts the intersection of case review and
compliance.
Figure A–1. Inspection Indicator Review Distribution for RJD
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of
its stakeholders, which continues in the Cycle 7 medical inspections. Below, Table A–1
provides important definitions that describe this process.
Table A–1. Case Review Definitions
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The OIG eliminates case review selection bias by sampling using a rigid methodology.
No case reviewer selects the samples he or she reviews. Because the case reviewers are
excluded from sample selection, there is no possibility of selection bias. Instead,
nonclinical analysts use a standardized sampling methodology to select most of the case
review samples. A randomizer is used when applicable.
For most basic institutions, the OIG samples 20 comprehensive physician review cases.
For institutions with larger high-risk populations, 25 cases are sampled. For the
California Health Care Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected institution and
from CCHCS. Our analysts then apply filters to identify clinically complex patients with
the highest need for medical services. These filters include patients classified by CCHCS
with high medical risk, patients requiring hospitalization or emergency medical services,
patients arriving from a county jail, patients transferring to and from other departmental
institutions, patients with uncontrolled diabetes or uncontrolled anticoagulation levels,
patients requiring specialty services or who died or experienced a sentinel event
(unexpected occurrences resulting in high risk of, or actual, death or serious injury),
patients requiring specialized medical housing placement, patients requesting medical
care through the sick call process, and patients requiring prenatal or postpartum care.
After applying filters, analysts follow a predetermined protocol and select samples for
clinicians to review. Our physician and nurse reviewers test the samples by performing
comprehensive or focused case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the clinicians review
medical records, they record pertinent interactions between the patient and the health
care system. We refer to these interactions as case review events. Our clinicians also
record medical errors, which we refer to as case review deficiencies.
Deficiencies can be minor or significant, depending on the severity of the deficiency. If a
deficiency caused serious patient harm, we classify the error as an adverse event. On the
next page, Figure A–2 depicts the possibilities that can lead to these different events.
After the clinician inspectors review all the cases, they analyze the deficiencies, then
summarize their findings in one or more of the health care indicators in this report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and compliance
inspectors. Analysts follow a detailed selection methodology. For most compliance
questions, we use sample sizes of approximately 25 to 30. Figure A–3 below depicts the
relationships and activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT) questions to
determine the institution’s compliance with CCHCS policies and procedures. Our nurse
inspectors assign a Yes or a No answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain information,
allowing them to answer most of the MIT questions. Our regional nurses visit and
inspect each institution. They interview health care staff, observe medical processes, test
the facilities and clinics, review employee records, logs, medical grievances, death
reports, and other documents, and obtain information regarding plant infrastructure and
local operating procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for each of the
questions applicable to a particular indicator, then averages the scores. The OIG
continues to rate these indicators based on the average compliance score using the
following descriptors: proficient (85.0 percent or greater), adequate (between 84.9 percent
and 75.0 percent), or inadequate (less than 75.0 percent).
Indicator Ratings and the Overall Medical
Quality Rating
The OIG medical inspection unit individually examines all the case review and
compliance inspection findings under each specific methodology. We analyze the case
review and compliance testing results for each indicator and determine separate overall
indicator ratings. After considering all the findings of each of the relevant indicators, our
medical inspectors individually determine the institution’s overall case review and
compliance ratings.
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Appendix B: Case Review Data
Table B–1. RJD Case Review Sample Sets
Sample Set Total
Anticoagulation 3
CTC/OHU 3
Death Review/Sentinel Events 3
Diabetes 3
Emergency Services – CPR 5
Emergency Services – Non-CPR 3
High Risk 5
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 28
Specialty Services 4
67
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Table B–2. RJD Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 8
Anticoagulation 5
Arthritis/Degenerative Joint Disease 16
Asthma 15
Cancer 5
Cardiovascular Disease 8
Chronic Kidney Disease 4
Chronic Pain 29
Cirrhosis/End Stage Liver Disease 10
Coccidioidomycosis 2
COPD 3
COVID-19 2
Deep Vein Thrombosis/Pulmonary Embolism 2
Diabetes 15
Gastroesophageal Reflux Disease 20
HIV 2
Hepatitis C 26
Hyperlipidemia 35
Hypertension 29
Mental Health 21
Seizure Disorder 3
Sleep Apnea 8
Substance Abuse 27
295
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Table B–3. RJD Case Review Events by Program
Diagnosis Total
Diagnostic Services 273
Emergency Care 89
Hospitalization 55
Intrasystem Transfers In 6
Intrasystem Transfers Out 4
Outpatient Care 515
Specialized Medical Housing 98
Specialty Services 246
1,286
Table B–4. RJD Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 25
MD Reviews Focused 3
RN Reviews Detailed 16
RN Reviews Focused 40
Total Reviews 84
Total Unique Cases 67
Overlapping Reviews (MD & RN) 17
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Appendix C: Compliance Sampling Methodology
Richard J. Donovan Correctional Facility
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least one
Patients condition per patient — any risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 35 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 25 OIG Q: 4.005 • See Health Information Management
Community (Medical Records) (returns from
Hospital community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001 – 003 Radiology 10 Radiology Logs • Appointment date
(90 days – 9 months)
• Randomize
• Abnormal
MITs 2.004 – 006 Laboratory 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 0 Quest • Appt. date (90 days – 9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology related)
• Randomize
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 35 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 25 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 25 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 11 OIG inspector • Identify and inspect all on-site clinical
MITs 5.107 – 111 on-site review areas
Transfers
MITs 6.001 – 003 Intrasystem Transfers 25 SOMS • Arrival date (3 – 9 months)
• Arrived from (another departmental
facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 6 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 • See Access to Care
Medication • At least one condition per patient —
any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of IPs tested in
MIT 7.001
MIT 7.003 Returns From 25 OIG Q: 4.005 • See Health Information Management
Community Hospital (Medical Records) (returns from
community hospital)
MIT 7.004 RC Arrivals — N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders
institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 10 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies by OIG inspector • Identify and inspect clinical & med
Areas test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies by OIG inspector • Identify and inspect on-site clinical
Preparation and test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 2 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 18 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit 20 On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications medication listing medications for IPs housed in
restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001 – 007 Recent Deliveries N/A at this OB Roster • Delivery date (2 – 12 months)
institution • Most recent deliveries (within date
range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2 – 12 months)
institution • Earliest arrivals (within date range)
Preventive Services
MITs 9.001 – 002 TB Medications 17 Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months
or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution
inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution
inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever N/A at this Cocci transfer • Reports from past 2 – 8 months
institution status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 007 RC N/A at this SOMS • Arrival date (2 – 8 months)
institution • Arrived from (county jail, return from
parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001 – 003 Specialized Health 10 CADDIS • Admit date (2 – 8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
• Rx count
• Randomize
MITs 13.101 – 102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, and radiology services
• Randomize
MITs 14.004 – 006 Medium-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, and radiology services
• Randomize
Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Specialty Services (continued)
MITs 14.007 – 009 Routine-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, and radiology services
• Randomize
MIT 14.010 Specialty Services 20 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 20 InterQual • Review date (3 – 9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events events report (2 – 8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC EMRRC meeting • Monthly meeting minutes
4
minutes (6 months)
MIT 15.004 LGB 4 LGB meeting • Quarterly meeting minutes
minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
MIT 15.103 Death Reports 10 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations (continued)
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 14 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 19 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site certification • All staff
Response tracking logs • Providers (ACLS)
Certifications • Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
MIT 15.109 Pharmacy and All On-site listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
document
MIT 15.110 Nursing Staff New All Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998 CCHCS Mortality 10 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
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California Correctional Health Care Services’
Response
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November 25, 2024, OIG Response to November 15, 2024,
Letter Regarding RJD Report
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Office of the Inspector General, State of California Inspection Period: December 2022 – May 2023 Report Issued: December 2024
Cycle 7
Medical Inspection Report
for
Richard J. Donovan Correctional Facility
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Neil Robertson
Chief Deputy Inspector General
STATE of CALIFORNIA
December 2024
OIG