OIG
California Substance Abuse Treatment Facility and State Prison, Corcoran Medical Inspection Report Cycle 5
Read the report at CDCR ↗
Roy W. Wesley
Office of the Inspector General
Inspector General
California Substance Abuse
Treatment Facility and
State Prison at Corcoran
Medical Inspection Results
Cycle 5
November 2017
Office of the Inspector General
CALIFORNIA SUBSTANCE ABUSE
TREATMENT FACILITY AND
STATE PRISON AT CORCORAN
Medical Inspection Results
Cycle 5
Roy W. Wesley
Inspector General
Shaun R. Spillane
Public Information Officer
November 2017
T C
ABLE OF ONTENTS
Forward ................................................................................................................................................ i
Executive Summary ............................................................................................................................ ii
Overall Rating: Adequate................................................................................................................. ii
Clinical Case Review and OIG Clinician Inspection Results ............................................... iv
Compliance Testing Results................................................................................................... v
Population-Based Metrics ..................................................................................................... vi
Recommendations ................................................................................................................ vii
Introduction ......................................................................................................................................... 1
About the Institution ........................................................................................................................ 1
Objectives, Scope, and Methodology.................................................................................................. 3
Case Reviews ................................................................................................................................... 4
Patient Selection for Retrospective Case Reviews ................................................................. 4
Benefits and Limitations of Targeted Subpopulation Review ............................................... 5
Case Reviews Sampled .......................................................................................................... 5
Compliance Testing ......................................................................................................................... 7
Sampling Methods for Conducting Compliance Testing ....................................................... 7
Scoring of Compliance Testing Results ................................................................................. 8
Overall Quality Indicator Rating for Case Reviews and Compliance Testing ................................ 8
Population-Based Metrics ................................................................................................................ 8
Medical Inspection Results ................................................................................................................. 9
1 — Access to Care ................................................................................................................. 11
Case Review Results ............................................................................................................ 11
Compliance Testing Results................................................................................................. 14
2 — Diagnostic Services ......................................................................................................... 17
Case Review Results ............................................................................................................ 17
Compliance Testing Results................................................................................................. 18
3 — Emergency Services ........................................................................................................ 20
Case Review Results ............................................................................................................ 20
4 — Health Information Management .................................................................................... 22
Case Review Results ............................................................................................................ 22
Compliance Testing Results................................................................................................. 23
5 — Health Care Environment ............................................................................................... 25
Compliance Testing Results................................................................................................. 25
6 — Inter- and Intra-System Transfers ................................................................................... 28
Case Review Results ............................................................................................................ 28
Compliance Testing Results................................................................................................. 29
7 — Pharmacy and Medication Management ........................................................................ 31
Case Review Results ............................................................................................................ 31
Compliance Testing Results................................................................................................. 32
8 — Prenatal and Post-Delivery Services .............................................................................. 36
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Table of Contents
Office of the Inspector General State of California
9 — Preventive Services ......................................................................................................... 37
Compliance Testing Results................................................................................................. 37
10 — Quality of Nursing Performance ................................................................................... 39
Case Review Results ............................................................................................................ 39
11 — Quality of Provider Performance .................................................................................. 43
Case Review Results ............................................................................................................ 43
12 — Reception Center Arrivals ............................................................................................. 47
13 — Specialized Medical Housing ........................................................................................ 48
Case Review Results ............................................................................................................ 48
Compliance Testing Results................................................................................................. 51
14 — Specialty Services .......................................................................................................... 52
Case Review Results ............................................................................................................ 52
Compliance Testing Results................................................................................................. 54
15 — Administrative Operations (Secondary) ........................................................................ 56
Compliance Testing Results................................................................................................. 56
Recommendations ............................................................................................................................. 59
Population-Based Metrics ................................................................................................................. 60
Appendix A — Compliance Test Results ......................................................................................... 63
Appendix B — Clinical Data ............................................................................................................ 76
Appendix C — Compliance Sampling Methodology ....................................................................... 80
California Correctional Health Care Services’ Response ................................................................. 87
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Table of Contents
Office of the Inspector General State of California
L T F
IST OF ABLES AND IGURES
SATF Executive Summary Table ...................................................................................................... iii
SATF Health Care Staffing Resources as of April, 2017 .................................................................... 2
SATF Master Registry Data as of April 24, 2017 ............................................................................... 2
SATF Results Compared to State and National HEDIS Scores ........................................................ 62
Table B-1: SATF Sample Sets ........................................................................................................... 76
Table B-2: SATF Chronic Care Diagnoses ....................................................................................... 77
Table B-3: SATF Event – Program ................................................................................................... 78
Table B-4: SATF Review Sample Summary ..................................................................................... 79
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection List of Tables and Figures
Office of the Inspector General State of California
F
ORWARD
Pursuant to California Penal Code Section 6126 et seq., which assigns the Office of the Inspector
General (OIG) responsibility for oversight of the California Department of Corrections and
Rehabilitation (CDCR), the OIG conducts a comprehensive inspection program to evaluate the
delivery of medical care at each of CDCR’s 35 adult prisons. The OIG explicitly makes no
determination regarding the constitutionality of care in the prison setting. That determination is left
to the Receiver and the federal court. The assessment of care by the OIG is just one factor in the
court’s determination whether care in the prisons meets constitutional standards.
The OIG’s inspections are mandated by the Penal Code and not aimed at specifically resolving the
court’s questions on constitutional care. To the degree that they provide another factor for the court
to consider, the OIG is pleased to provide added value to the taxpayers of California.
In Cycle 5, for the first time, the OIG will be inspecting institutions delegated back to CDCR from
the Receivership. There is no difference in the standards used for assessment of a delegated
institution versus an institution not yet delegated. At the time of the Cycle 5 inspection of the
California Substance Abuse Treatment Facility and State Prison at Corcoran (SATF), the Receiver
had not delegated this institution back to CDCR.
This fifth cycle of inspections will continue evaluating the areas addressed in Cycle 4, which
included clinical case review, compliance testing, and a population-based metric comparison of
selected Healthcare Effectiveness Data Information Set (HEDIS) measures. In agreement with
stakeholders, the OIG made changes to both the case review and compliance components. The OIG
found that in every inspection in Cycle 4, larger samples were taken than were needed to assess the
adequacy of medical care provided. As a result, the OIG reduced the number of case reviews and
sample sizes for compliance testing. Also, in Cycle 4, compliance testing included two secondary
(administrative) indicators (Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications). For Cycle 5, these have
been combined into one secondary indicator, Administrative Operations.
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E S
XECUTIVE UMMARY
The OIG performed its Cycle 5 medical inspection at the California
Substance Abuse Treatment Facility and State Prison at Corcoran
(SATF) from May to July 2017. The inspection included in-depth
OVERALL RATING:
reviews of 64 patient files conducted by clinicians, as well as
Adequate
reviews of documents from 432 patient files, covering
91 objectively scored tests of compliance with policies and
procedures applicable to the delivery of medical care. The OIG
assessed the case review and compliance results at SATF using
13 health care quality indicators applicable to the institution, To
conduct clinical case reviews, the OIG employs a clinician team consisting of a physician and a
registered nurse consultant, while compliance testing is done by a team of registered nurses trained
in monitoring medical policy compliance. Of the indicators, seven were rated by both case review
clinicians and compliance inspectors, three were rated by case review clinicians only, and three
were rated by compliance inspectors only. The SATF Executive Summary Table on the following
page identifies the applicable individual indicators and scores for this institution.
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SATF Executive Summary Table
Cycle 5 Cycle 4
Case Review Compliance
Inspection Indicators Overall Overall
Rating Rating
Rating Rating
1—Access to Care Adequate Inadequate Inadequate Adequate
2—Diagnostic Services Adequate Inadequate Adequate Adequate
3—Emergency Services Adequate Not Applicable Adequate Adequate
4—Health Information
Adequate Inadequate Inadequate Adequate
Management
5—Health Care Environment Not Applicable Inadequate Inadequate Adequate
6—Inter- and Intra-System
Adequate Adequate Adequate Adequate
Transfers
7—Pharmacy and Medication
Adequate Inadequate Inadequate Inadequate
Management
8—Prenatal and Post-Delivery
Not Applicable Not Applicable Not Applicable Not Applicable
Services
9—Preventive Services Not Applicable Adequate Adequate Inadequate
10—Quality of Nursing
Adequate Not Applicable Adequate Adequate
Performance
11—Quality of Provider
Adequate Not Applicable Adequate Adequate
Performance
12—Reception Center Arrivals Not Applicable Not Applicable Not Applicable Not Applicable
13—Specialized Medical Housing Adequate Adequate Adequate Inadequate
14—Specialty Services Adequate Inadequate Adequate Adequate
15—Administrative Operations
Not Applicable Adequate Adequate Inadequate*
(Secondary)
*In Cycle 4, there were two secondary (administrative) indicators. This score reflects the average of those
two scores.
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Office of the Inspector General State of California
Clinical Case Review and OIG Clinician Inspection Results
The clinicians’ case reviews sampled patients with high medical needs and included a review of
more than 1,531 patient care events.1 Of the 13 indicators applicable to SATF, 10 were evaluated by
clinician case review; all ten were rated adequate. When determining the overall adequacy of care,
the OIG paid particular attention to the clinical nursing and provider quality indicators, as adequate
health care staff can sometimes overcome suboptimal processes and programs. However, the
opposite is not true; inadequate health care staff cannot provide adequate care, even though the
established processes and programs onsite may be adequate. The OIG clinicians identify inadequate
medical care based on the risk of significant harm to the patient, not the actual outcome.
Program Strengths — Clinical
Providers had high morale and felt supported by their leadership.
SATF nursing care coordinators scheduled follow-up care for patients referred to them, and
were usually able to consult with providers to resolve issues that required planning for
higher levels of care.
Nurses reviewed patient health care service requests timely and appropriately. Nursing staff
typically scheduled and saw patients in the same day the patient turned in the request form.
Program Weaknesses — Clinical
Provider care in the CTC was sometimes poor. Many significant deficiencies arose when
providers failed to adequately review medical records or failed to attempt to retrieve missing
community hospital discharge summaries. Despite being classified as a basic institution,
SATF had many complex patients, especially in the CTC, who required additional time and
skilled provider care.
Nursing assessments were incomplete in multiple patient cases reviewed. In some cases, the
nurse did not identify the urgency of the condition or appropriately refer the patient to a
provider.
As was the case in Cycle 4, health information management staff frequently scanned
documents into the electronic medical record without a provider’s review or signature.
1 Each OIG clinician team includes a board-certified physician and registered nurse consultant with experience in
correctional and community medical settings.
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Compliance Testing Results
Of the 13 health care indicators applicable to SATF, 10 were evaluated by compliance inspectors.2
Four were adequate, and six were inadequate. There were 91 individual compliance questions
within those 10 indicators, generating 1,227 data points, that tested SATF’s compliance with
California Correctional Health Care Services (CCHCS) policies and procedures.3 Those 91
questions are detailed in Appendix A — Compliance Test Results.
Program Strengths — Compliance
The following are some of SATF’s strengths based on its compliance scores on individual questions
in all the health care indicators:
Nursing staff reviewed patient health care services requests and provided face-to-face
encounters within required time frames.
Registered nurses (RNs) completed the assessment and disposition sections of initial health
care assessment forms for patients that transferred into SATF, and nursing staff properly
completed medication transfer packages for patients that transferred out of SATF.
The institution’s main pharmacy followed proper security, organization, and cleanliness
protocols, properly stored medications, and had strong controls in place for narcotic
medications.
SATF timely offered immunizations and colon cancer screenings to patients.
The institution provided high-priority and routine specialty services within required time
frames.
The institution timely addressed patient’s medical appeals and properly reviewed
Emergency Medical Response Review Committee (EMRRC) minutes, in compliance with
policy.
2 The OIG’s compliance inspectors are trained registered nurses with expertise in CDCR policies regarding medical
staff and processes.
3 The OIG used its own clinicians to provide clinical expert guidance for testing compliance in certain areas where
CCHCS policies and procedures did not specifically address an issue.
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Program Weaknesses — Compliance
The following are some of the weaknesses identified by SATF’s compliance scores on individual
questions in all the health care indicators:
Providers did a poor job communicating diagnostic service results to patients.
Clinicians at several SATF clinics did not follow good hand hygiene practices, and protocols
to protect against blood borne pathogens were weak; inspectors found clinics that did not
have sharps containers, or the sharps containers were not properly maintained.
Several medication line locations had poor inventory count controls over narcotic
medication, and several locations did not properly store non-narcotic medications.
The institution did not always timely receive, and providers did not always timely review,
routine and high-priority specialty service reports.
Population-Based Metrics
In general, SATF performed as well as or better than other entities reporting data, both statewide
and nationally, in many areas measured by population-based metrics. In comprehensive diabetes
care, for example, SATF outscores most State and nationwide health plans, while scoring less well
in just a few measures; specifically, eye exams. With regard to immunizations and cancer screening,
the institution scored lower than most of the other health care plans, but the high patient refusal rate
negatively affected the institution’s scores. SATF can improve their scores in these measures by
educating patients on the benefits of these preventive services.
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Recommendations
The OIG recommends SATF provide training for health information management staff to
ensure reports are reviewed and signed by providers prior to being scanned into medical
records. When the EHRS is implemented, SATF should ensure that the health information
management staff sends reports to providers for their review and signature electronically.
The OIG recommends SATF leadership deliver training to providers regarding careful
review of medical records for complex patients, such as those cared for in the CTC. This is
especially important for providers who are unfamiliar with the patients because the
providers are on call or covering on weekends. In addition, the OIG recommends that SATF
train providers about the importance of careful record review for patients returning from
outside hospitals to ensure that all diagnoses and management plans are appropriately
addressed.
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Office of the Inspector General State of California
I
NTRODUCTION
Pursuant to California Penal Code Section 6126 et seq., which assigns the Office of the Inspector
General (OIG) responsibility for oversight of the California Department of Corrections and
Rehabilitation (CDCR), and at the request of the federal Receiver, the OIG developed a
comprehensive medical inspection program to evaluate the delivery of medical care at each of
CDCR’s 35 adult prisons. The OIG conducts a clinical case review and a compliance inspection,
ensuring a thorough, end-to-end assessment of medical care within CDCR.
The California Substance Abuse Treatment Facility and State Prison at Corcoran (SATF) was the
13th medical inspection of Cycle 5. During the inspection process, the OIG assessed the delivery of
medical care to patients using the primary clinical health care indicators applicable to the institution.
The Administrative Operations indicator is secondary because it does not reflect the actual clinical
care provided.
ABOUT THE INSTITUTION
Located in Corcoran, Kings County, SATF operates as a medium-to-high-security, and
maximum-security institution for general population inmates. SATF runs multiple medical clinics
where staff members address routine requests for medical services. SATF also conducts patient
screenings in its receiving and release clinic (R&R), treats patients requiring urgent or emergent
care in its triage and treatment area (TTA), and houses patients requiring inpatient health care
services in its correctional treatment center (CTC). SATF has been designated as a “basic care
institution” by CDCR. Basic care institutions are located in rural areas away from tertiary care
centers and specialty care providers whose services are likely to be used frequently by higher-risk
patients. Basic care institutions have the capability to provide limited specialty medical services and
consultation for a generally healthy inmate-patient population.
On January 28, 2016, the institution received national accreditation from the Commission on
Accreditation for Corrections. This accreditation program is a professional peer review process
based on national standards set by the American Correctional Association.
Based on staffing data the OIG obtained from the institution, SATF’s vacancy rate among medical
managers, primary care providers, supervisors, and rank-and-file nurses was 9 percent in April
2017, with the highest vacancy percentage among primary care providers at 23 percent, which
correlated to 3 vacancies out of 13 authorized positions.
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Office of the Inspector General State of California
SATF Health Care Staffing Resources as of April, 2017
Primary Care Nursing
Management Nursing Staff Totals
Providers Supervisors
Description Number % Number % Number % Number % Number %
Authorized
5 2% 13 6% 14.3 6% 130.2 80% 162.5 100%
Positions
Filled Positions 5 100% 10 77% 14 98% 119.6 92% 148.6 91%
Vacancies 0 0% 3 23% 0.3 2% 10.6 8% 13.9 9%
Recent Hires
(within 12 0 0% 1 10% 6 43% 16 9% 23 11%
months)
Staff Utilized
0 0% 0 0% 0 0% 19 11% 19 9%
from Registry
Redirected Staff
(to Non-Patient 0 0% 0 0% 0 0% 3 2% 3 1%
Care Areas)
Staff on
Long-term 0 0% 0 0% 0 % 12 7% 12 6%
Medical Leave
Note: SATF Health Care Staffing Resources data was not validated by the OIG.
As of April 24, 2017, the Master Registry for SATF showed that the institution had a total
population of 5,634. Within that total population, 2.2 percent were designated as high medical risk,
Priority 1 (High 1), and 5.5 percent were designated as high medical risk, Priority 2 (High 2).
Patients’ assigned risk levels are based on the complexity of their required medical care related to
their specific diagnoses, frequency of higher levels of care, age, and abnormal laboratory results and
procedures. High 1 has at least two high-risk conditions; High 2 has only one. Patients at high
medical risk are more susceptible to poor health outcomes than those at medium or low medical
risk. Patients at high medical risk also typically require more health care services than do patients
with lower assigned risk levels. The chart below illustrates the breakdown of the institution’s
medical risk levels at the start of the OIG medical inspection.
SATF Master Registry Data as of April 24, 2017
Medical Risk Level # of Patients Percentage
High 1 126 2.2%
High 2 308 5.5%
Medium 3,091 54.9%
Low 2,109 37.4%
Total 5,634 100%
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O , S , M
BJECTIVES COPE AND ETHODOLOGY
In designing the medical inspection program, the OIG reviewed CCHCS policies and procedures,
relevant court orders, and guidance developed by the American Correctional Association. The OIG
also reviewed professional literature on correctional medical care; reviewed standardized
performance measures used by the health care industry; consulted with clinical experts; and met
with stakeholders from the court, the Receiver’s office, CDCR, the Office of the Attorney General,
and the Prison Law Office to discuss the nature and scope of the OIG’s inspection program. With
input from these stakeholders, the OIG developed a medical inspection program that evaluates
medical care delivery by combining clinical case reviews of patient files, objective tests of
compliance with policies and procedures, and an analysis of outcomes for certain population-based
metrics.
To maintain a metric-oriented inspection program that evaluates medical care delivery consistently
at each state prison, the OIG identified 15 indicators (14 primary (clinical) indicators and one
secondary (administrative) indicator) of health care to measure. The primary quality indicators
cover clinical categories directly relating to the health care provided to patients, whereas the
secondary quality indicator address the administrative functions that support a health care delivery
system. These 15 indicators are identified in the SATF Executive Summary Table on page iii of this
report.
The OIG rates each of the quality indicators applicable to the institution under inspection based on
case reviews conducted by OIG clinicians and compliance tests conducted by OIG registered
nurses. The ratings may be derived from the case review results alone, the compliance test results
alone, or a combination of both these information sources. For example, the ratings for the primary
quality indicators Quality of Nursing Performance and Quality of Provider Performance are derived
entirely from the case review done by clinicians, while the ratings for the primary quality indicators
Health Care Environment and Preventive Services are derived entirely from compliance testing
done by registered nurse inspectors. As another example, primary quality indicators such as
Diagnostic Services and Specialty Services receive ratings derived from both sources.
Consistent with the OIG’s agreement with the Receiver, this report only addresses the conditions
found related to medical care criteria. The OIG does not review for efficiency and economy of
operations. Moreover, if the OIG learns of a patient needing immediate care, the OIG notifies the
chief executive officer of health care services and requests a status report. Additionally, if the OIG
learns of significant departures from community standards, it may report such departures to the
institution’s chief executive officer or to CCHCS. Because these matters involve confidential
medical information protected by state and federal privacy laws, specific identifying details related
to any such cases are not included in the OIG’s public report.
In all areas, the OIG is alert for opportunities to make appropriate recommendations for
improvement. Such opportunities may be present regardless of the score awarded to any particular
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Office of the Inspector General State of California
quality indicator; therefore, recommendations for improvement should not necessarily be
interpreted as indicative of deficient medical care delivery.
CASE REVIEWS
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of its
stakeholders, which continues in Cycle 5 medical inspections. The OIG’s clinicians perform a
retrospective chart review of selected patient files to evaluate the care given by an institution’s
primary care providers and nurses. Retrospective chart review is a well-established review process
used by health care organizations that perform peer reviews and patient death reviews. Currently,
CCHCS uses retrospective chart review as part of its death review process and in its
pattern-of-practice reviews. CCHCS also uses a more limited form of retrospective chart review
when performing appraisals of individual primary care providers.
Patient Selection for Retrospective Case Reviews
Because retrospective chart review is time consuming and requires qualified health care
professionals to perform it, OIG clinicians must carefully sample patient records. Accordingly, the
group of patients the OIG targeted for chart review carried the highest clinical risk and utilized the
majority of medical services. A majority of the patients selected for retrospective chart review were
classified by CCHCS as high-risk patients. The reason the OIG targeted these patients for review is
twofold:
1. The goal of retrospective chart review is to evaluate all aspects of the health care system.
Statewide, high-risk and high-utilization patients consume medical services at a
disproportionate rate; 11 percent of the total patient population are considered high-risk and
account for more than half of the institution’s pharmaceutical, specialty, community
hospital, and emergency costs.
2. Selecting this target group for chart review provides a significantly greater opportunity to
evaluate all the various aspects of the health care delivery system at an institution.
Underlying the choice of high-risk patients for detailed case review, the OIG clinical experts made
the following three assumptions:
1. If the institution is able to provide adequate clinical care to the most challenging patients
with multiple complex and interdependent medical problems, it will be providing adequate
care to patients with less complicated health care issues. Because clinical expertise is
required to determine whether the institution has provided adequate clinical care, the OIG
utilizes experienced correctional physicians and registered nurses to perform this analysis.
2. The health of less complex patients is more likely to be affected by processes such as timely
appointment scheduling, medication management, routine health screening, and
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immunizations. To review these processes, the OIG simultaneously performs a broad
compliance review.
3. Patient charts generated during death reviews, sentinel events (unexpected occurrences
involving death or serious injury, or risk thereof), and hospitalizations are mostly of
high-risk patients.
Benefits and Limitations of Targeted Subpopulation Review
Because the selected patients utilize the broadest range of services offered by the health care
system, the OIG’s retrospective chart review provides adequate data for a qualitative assessment of
the most vital system processes (referred to as “primary quality indicators”). Retrospective chart
review provides an accurate qualitative assessment of the relevant primary quality indicators as
applied to the targeted subpopulation of high-risk and high-utilization patients. While this targeted
subpopulation does not represent the prison population as a whole, the ability of the institution to
provide adequate care to this subpopulation is a crucial and vital indicator of how the institution
provides health care to its whole patient population. Simply put, if the institution’s medical system
does not adequately care for those patients needing the most care, then it is not fulfilling its
obligations, even if it takes good care of patients with less complex medical needs.
Since the targeted subpopulation does not represent the institution’s general prison population, the
OIG cautions against inappropriate extrapolation of conclusions from the retrospective chart
reviews to the general population. For example, if the high-risk diabetic patients reviewed have
poorly-controlled diabetes, one cannot conclude that the entire diabetic population is inadequately
controlled. Similarly, if the high-risk diabetic patients under review have poor outcomes and require
significant specialty interventions, one cannot conclude that the entire diabetic population is having
similarly poor outcomes.
Nonetheless, the health care system’s response to this subpopulation can be accurately evaluated
and yields valuable systems information. In the above example, if the health care system is
providing appropriate diabetic monitoring, medication therapy, and specialty referrals for the
high-risk patients reviewed, then it can be reasonably inferred that the health care system is also
providing appropriate diabetic services to the entire diabetic subpopulation. However, if these same
high-risk patients needing monitoring, medications, and referrals are generally not getting those
services, it is likely that the health care system is not providing appropriate diabetic services to the
greater diabetic subpopulation.
Case Reviews Sampled
As indicated in Appendix B, Table B–1: SATF Sample Sets, the OIG clinicians evaluated medical
charts for 64 unique patients. Appendix B, Table B–4: SATF Case Review Sample Summary clarifies
that both nurses and physicians reviewed charts for 15 of those patients, for 79 reviews in total.
Physicians performed detailed reviews of 25 charts, and nurses performed detailed reviews of 15
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charts, totaling 40 detailed reviews. For detailed case reviews, physicians or nurses looked at all
encounters occurring in approximately six months of medical care. Nurses also performed a limited
or focused review of medical records for an additional 39 patients. These generated 1,531 clinical
events for review (Appendix B, Table B–3: SATF Event – Program). The inspection tool provides
details on whether the encounter was adequate or had significant deficiencies, and identifies
deficiencies by programs and processes to help the institution focus on improvement areas.
While the sample method specifically pulled only 6 chronic care patient records, i.e., 3 diabetes
patients and 3 anticoagulation patients (Appendix B, Table B–1: SATF Sample Sets), the 64 unique
patients sampled included patients with 197 chronic care diagnoses, including 17 additional patients
with diabetes (for a total of 20) and one additional anticoagulation patient (for a total of 4)
(Appendix B, Table B–2: SATF Chronic Care Diagnoses). The OIG’s sample selection tool allowed
evaluation of many chronic care programs because the complex and high-risk patients selected from
the different categories often had multiple medical problems. While the OIG did not evaluate every
chronic disease or health care staff member, the overall operation of the institution’s system and
staff were assessed for adequacy.
The OIG’s case review methodology and sample size matched other qualitative research. The
empirical findings, supported by expert statistical consultants, showed adequate conclusions after 10
to 15 charts had undergone full clinician review. In qualitative statistics, this phenomenon is known
as “saturation.” The OIG found the Cycle 4 medical inspection sample size of 30 for detailed
physician reviews far exceeded the saturation point necessary for an adequate qualitative review. At
the end of Cycle 4 inspections, the case review results were reanalyzed using 50 percent of the
cases; there were no significant differences in the ratings. To improve inspection efficiency while
preserving the quality of the inspection, the samples for Cycle 5 medical inspections were reduced
in number. In Cycle 5, for basic institutions with small high-risk populations, case review will use a
sample size of detailed physician-reviewed cases 67 percent as large as that used in Cycle 4. For
intermediate institutions and basic institutions housing many high-risk patients, case review
physicians will use a sample 83 percent as large as that in Cycle 4. For SATF, the OIG used a
sample size 83 percent as large as that used in Cycle 4 because SATF had many high-risk patients.
Finally, for the most medically complex institution, California Health Care Facility (CHCF), the
OIG will continue to use a sample size 100 percent as large as that used in Cycle 4.
With regard to reviewing charts from different providers, the case review is not intended to be a
focused search for poorly performing providers; rather, it is focused on how the system cares for
those patients who need care the most. Nonetheless, while not sampling cases by each provider at
the institution, the OIG inspections adequately review most providers. Providers would only escape
OIG case review if institutional management successfully mitigated patient risk by having the more
poorly performing providers care for the less complicated, low-utilizing, and lower-risk patients.
The OIG’s clinicians concluded that the case review sample size was more than adequate to assess
the quality of services provided.
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Based on the collective results of clinicians’ case reviews, the OIG rated each quality indicator as
either proficient (excellent), adequate (passing), inadequate (failing), or not applicable. A separate
confidential SATF Supplemental Medical Inspection Results: Individual Case Review Summaries
report details the case reviews OIG clinicians conducted and is available to specific stakeholders.
For further details regarding the sampling methodologies and counts, see Appendix B — Clinical
Data, Table B–1; Table B–2; Table B–3; and Table B–4.
COMPLIANCE TESTING
Sampling Methods for Conducting Compliance Testing
From May to July 2017, registered nurse inspectors attained answers to 91 objective medical
inspection test (MIT) questions designed to assess the institution’s compliance with critical policies
and procedures applicable to the delivery of medical care. To conduct most tests, inspectors
randomly selected samples of patients for whom the testing objectives were applicable and
reviewed their electronic medical records. In some cases, inspectors used the same samples to
conduct more than one test. In total, inspectors reviewed medical records for 432 individual patients
and analyzed specific transactions within their records for evidence that critical events occurred.
Inspectors also reviewed management reports and meeting minutes to assess certain administrative
operations. In addition, during the week of May 15, 2017, registered nurse field inspectors
conducted a detailed onsite inspection of SATF’s medical facilities and clinics; interviewed key
institutional employees; and reviewed employee records, logs, medical appeals, death reports, and
other documents. This generated 1,227 scored data points to assess care.
In addition to the scored questions, the OIG obtained information from the institution that it did not
score. This included, for example, information about SATF’s plant infrastructure, protocols for
tracking medical appeals and local operating procedures, and staffing resources.
For Cycle 5 medical inspection testing, the OIG reduced the number of compliance samples tested
for 18 indicator tests from a sample of 30 patients to a sample of 25 patients. The OIG also removed
some inspection tests upon stakeholder agreement that either were duplicated in the case reviews or
had limited value. Lastly, for Cycle 4 medical inspections, the OIG tested two secondary
(administrative) indicators; Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications, and have combined
these tests into one Administrative Operations indicator for Cycle 5 inspections.
For details of the compliance results, see Appendix A — Compliance Test Results. For details of the
OIG’s compliance sampling methodology, see Appendix C — Compliance Sampling Methodology.
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Scoring of Compliance Testing Results
After compiling the answers to the 91 questions for the 10 applicable indicators, the OIG derived a
score for each quality indicator by calculating the percentage score of all Yes answers for each of
the questions applicable to a particular indicator, then averaging those scores. Based on those
results, the OIG assigned a rating to each quality indicator of proficient (greater than 85 percent),
adequate (between 75 percent and 85 percent), or inadequate (less than 75 percent).
OVERALL QUALITY INDICATOR RATING FOR CASE REVIEWS AND COMPLIANCE
TESTING
The OIG derived the final rating for each quality indicator by combining the ratings from the case
reviews and from the compliance testing, as applicable. When combining these ratings, the case
review evaluations and the compliance testing results usually agreed, but there were instances when
the rating differed for a particular quality indicator. In those instances, the inspection team assessed
the quality indicator based on the collective ratings from both components. Specifically, the OIG
clinicians and registered nurse inspectors discussed the nature of individual exceptions found within
that indicator category and considered the overall effect on the ability of patients to receive
adequate medical care.
To derive an overall assessment rating of the institution’s medical inspection, the OIG evaluated the
various rating categories assigned to each of the quality indicators applicable to the institution,
giving more weight to the rating results of the primary quality indicators, which directly relate to the
health care provided to patients. Based on that analysis, OIG experts made a considered and
measured overall opinion about the quality of health care observed.
POPULATION-BASED METRICS
The OIG identified a subset of Healthcare Effectiveness Data Information Set (HEDIS) measures
applicable to the CDCR patient population. To identify outcomes for SATF, the OIG reviewed
some of the compliance testing results, randomly sampled additional patients’ records, and obtained
SATF’s data from the CCHCS Master Registry. The OIG compared those results to HEDIS metrics
reported by other statewide and national health care organizations.
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M I R
EDICAL NSPECTION ESULTS
The quality indicators assess the clinical aspects of health care. As shown on the SATF Executive
Summary Table on page iii of this report, 13 of the OIG’s indicators were applicable to SATF. Of
those 13 indicators, 7 were rated by both the case review and compliance components of the
inspection, 3 were rated by the case review component alone, and 3 were rated by the compliance
component alone. The Administrative Operations indicator is a secondary indicator, and, therefore,
was not relied upon for the overall score for the institution. Based on the analysis and results in all
the primary indicators, the OIG experts made a considered and measured opinion that the quality of
health care at SATF was adequate.
Summary of Case Review Results
The clinical case review component assessed 10 of the 13 indicators applicable to SATF. Of these
10 indicators, OIG clinicians rated all 10 adequate.
The OIG physicians rated the overall adequacy of care for each of the 25 detailed case reviews they
conducted. Of these 25 cases, 21 were adequate, and 4 were inadequate. In the 1,531 events
reviewed, there were 241 deficiencies, of which 39 were considered to be of such magnitude that, if
left unaddressed, they would likely contribute to patient harm.
Adverse Events Identified During Case Review
Adverse events are medical errors that are more likely than not to cause grave patient harm.
Medical care is a complex and dynamic process with many moving parts, subject to human error
even within the best health care organizations. Adverse events are typically identified and tracked
by all major health care organizations for the purpose of quality improvement. They are not
generally representative of medical care delivered by the organization. The OIG identified adverse
events for the dual purposes of quality improvement and the illustration of problematic patterns of
practice found during the inspection. Because of the anecdotal description of these events, the OIG
cautions against drawing inappropriate conclusions regarding the institution based solely on adverse
events.
There were two adverse events identified in case 22. This was a complex patient with end-stage
heart disease and multiple-organ failure. Most of his care was adequate, but during the final weeks
of care, SATF clinicians did not adequately manage the patient’s care. These errors likely led to the
patient’s untimely death. Different aspects of this patient’s care are discussed in multiple areas
within this report, including the Emergency Services, Inter- and Intra-System Transfers, Pharmacy
and Medication Management, Quality of Provider Performance, and the Specialized Medical
Housing indicators.
In case 22, the patient developed severe shortness of breath and chest pressure. The provider
waited 75 minutes before ordering an EKG, and did not decide to send the patient to the
hospital for a possible heart attack until more than two hours after the patient presented with
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chest discomfort and breathing difficulty. The patient did not transfer out of the facility until
more than four hours after he had presented with his symptoms. The OIG considered this
severe delay an adverse event.
One month later (case 22), the patient was again hospitalized for worsening breathing
problems. He was found to have blood clots in his lungs and required anticoagulation
treatment. The hospital recommended two anticoagulation medications. SATF providers
neglected to order either of the anticoagulation medications, and the patient did not receive
these critical medications until five days later. Nurses later missed an administration of
enoxaparin, one of the critical anticoagulation medications, which further increased the
patient’s risk of blood clot complications. The OIG also considered these errors an adverse
event. The patient subsequently died in the hospital of worsening heart failure.
Summary of Compliance Results
The compliance component assessed 10 of the 13 indicators applicable to SATF. Of these 10
indicators, OIG inspectors rated none proficient, four adequate, and six inadequate. The results of
those assessments are summarized within this section of the report. The test questions used to assess
compliance for each indicator are detailed in Appendix A.
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1 — ACCESS TO CARE
This indicator evaluates the institution’s ability to provide patients
Case Review Rating:
with timely clinical appointments. Areas specific to patients’ access
Adequate
to care are reviewed, such as initial assessments of newly arriving Compliance Score:
inmates, acute and chronic care follow-ups, face-to-face nurse Inadequate
appointments when a patient requests to be seen, provider referrals (71.7%)
from nursing lines, and follow-ups after hospitalization or specialty Overall Rating:
care. Compliance testing for this indicator also evaluates whether Inadequate
patients have Health Care Services Request forms (CDCR Form
7362) available in their housing units.
In this indicator, the OIG case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance review resulting in an
inadequate score. The OIG’s internal review process considered those factors that led to both scores
and ultimately rated this indicator inadequate, placing a heavier reliance on compliance testing. The
case review assessments mainly focused on high-risk patients and targeted more recent patient
appointments, but the compliance review randomly selected patients across various categories and
evaluated the timeliness of appointments from two weeks to nine months prior to the inspection;
this provided a more robust assessment of patients’ access to medical care at SATF. In addition,
compliance testing yielded extremely poor results in provider follow-up timeliness. Delays occurred
in chronic care appointments, RN-to-provider referrals, provider follow-ups after specialty services,
and provider appointments for patients new to the institution. As a result, an inadequate overall
rating was deemed appropriate for this indicator.
Case Review Results
For the Access to Care indicator, the OIG clinicians reviewed 544 provider, nurse, specialty, and
hospital events that required follow-up appointments, among which there were 22 deficiencies.
Fifteen of the 22 deficiencies were significant.
RN Sick Call Access
SATF performed well with RN sick call access. At the onsite inspection, staff stated there were no
backlogs in nursing appointments.
Provider-to-Provider Follow-up Appointments
Patients generally received timely appointments after providers ordered them. Among the 101
outpatient provider appointments reviewed, the OIG identified only five deficiencies, of which two
were significant:
In case 6, the patient was a high-risk patient with prior heart attacks and a stroke. The patient
had uncontrolled blood pressure. The provider ordered a chronic care follow-up visit within
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four weeks, but the appointment did not occur, resulting in a severe lapse in care. Although
the patient was also non-compliant with some medical recommendations, it is possible that
the lapse in care contributed to the patient’s sudden death, which had no clear cause.
In case 15, the on-call provider conducted an emergent encounter with the patient for chest
pain and shortness of breath. The provider ordered a next-day follow-up, but the
appointment did not occur. Fortunately, the patient’s symptoms resolved and no harm
occurred.
Nurse-to-Provider Referrals
There was a pattern of delayed provider appointments after nurse referrals. The OIG reviewed 26
events in which the nurse referred the patient to the provider. Five deficiencies were identified in
these events, four of which were significant:
In case 22, the patient saw the nurse for follow-up of a recent X-ray report showing that the
patient had pneumonia. The nurse consulted the primary care provider, who ordered
antibiotics and a follow-up appointment in seven days. The appointment did not occur.
In case 39, the patient saw the nurse for complaints about side effects from one of his
medications. The nurse referred the patient to the provider to be seen in three days, but the
patient was not seen until one month later.
In case 44, the patient saw the nurse for foot pain and swelling from shoes prescribed by the
specialist. The nurse referred the patient to the provider, but the appointment did not occur,
and the problem was not addressed.
In case 49, the patient saw the nurse for weakness, vomiting, and chronic fatigue. The nurse
referred the patient to a provider, but the appointment did not occur.
Nursing Follow-up Appointments
In general, nurses timely saw patients who were referred for nursing follow-up. Among the 20 RN
referrals reviewed, there was only one minor deficiency whereby the RN appointment was delayed
(case 14).
Provider Follow-up After Specialty Services
Providers appropriately saw their patients after specialty services. The OIG reviewed 96 specialty
appointments and procedures that required a provider follow-up. There was no pattern of problems
identified in this area. There was only one significant deficiency:
In case 43, the provider follow-up appointment to review an urgent CT of the neck should
have occurred within 3 days, but was 13 days late.
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Intra-System Transfers
SATF performed adequately ensuring that patients who transferred in from other CDCR facilities
were given timely provider appointments. The OIG clinicians reviewed 19 transfer-in events and
found one minor deficiency.
Follow-up After Hospitalization
SATF ensured that providers saw their patients after outside hospitalizations or emergency room
visits. The OIG clinicians reviewed 25 of these events, and all patients who returned from the
hospital or emergency room received a provider follow-up appointment.
Follow-up After Urgent/Emergent Care
Providers appropriately saw their patients after TTA visits. The OIG reviewed 12 cases in which the
patient went to the TTA, returned to housing, and required a provider follow-up appointment. The
OIG found one significant deficiency:
In case 17, the patient was seen in the TTA for severe back pain. The TTA provider treated
the patient and ordered a provider follow-up within five days. The appointment did not
occur until more than three weeks later. Fortunately, the patient’s symptoms did not worsen.
Specialized Medical Housing
Providers admitted patients quickly to the CTC and saw them regularly. The OIG clinicians
reviewed 4 CTC admissions and 313 CTC provider encounters. There was one significant
deficiency:
In case 17, the patient had a long, complex stay in the CTC for management of osteomyelitis
(bone infection) of the spine. After he was discharged from the CTC, there was no provider
follow-up, and the patient was lost to follow-up until the OIG’s intervention during the
onsite clinician visit.
Specialty Access and Follow-up
SATF performed adequately with specialty service access. Performance in this area is further
discussed in the Specialty Services indicator. There was one significant deficiency:
In case 2, the patient required a neurology consultation after being hospitalized for a seizure
disorder. This appointment did not occur.
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Diagnostic Results Follow-up
SATF performed adequately with provider follow-ups after abnormal laboratory results. There was
only one significant deficiency:
In case 34, the provider ordered a follow-up appointment after reviewing abnormal
laboratory results. The appointment was not scheduled.
Clinician Onsite Inspection
The OIG clinicians interviewed SATF leadership and staff regarding access to care. Despite
adequate case review performance, many of the yards had patient appointment backlogs caused
because of three provider vacancies in the last six months. At the time of the onsite inspection, the
vacancies had been filled. In addition, the backlogs decreased with the chief medical executive
(CME) starting weekend clinics to catch up. SATF had also started using CCHCS telemedicine
providers for primary care services to further reduce the backlogs. While improvements were made,
the CME was concerned that the current staffing, even with all vacancies filled, was still
insufficient. Classified by CCHCS as a basic institution, SATF nevertheless housed an
approximately 10 percent high-risk medical population and a rising enhanced outpatient (EOP)
population, both of which required additional provider resources.
Case Review Conclusion
The institution performed adequately with outpatient RN and provider access as well as follow-ups
after specialty services, hospitalizations, and TTA services. CTC and specialty access was also
adequate. There were problems with provider access after referral from the sick call nurse. The case
review rating of the Access to Care indicator was adequate.
Compliance Testing Results
The institution performed in the inadequate range in the Access to Care indicator, with a
compliance score of 71.7 percent. Several areas showed room for improvement:
Among 24 sampled patients who suffered from one or more chronic care conditions, only 8
timely received their provider-ordered follow-up appointments (33 percent); 16 other
patients received their appointments late or not at all. Three patients’ follow-up
appointments occurred between one and seven days late; six patients’ appointments were
from 10 to 51 days late; and two patients’ appointments were 107 and 179 days late. For five
patients, there was no evidence that they were seen at all (MIT 1.001).
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Among the 21 Health Care Services Request forms (CDCR Form 7362) sampled on which
nursing staff referred the patient for a provider appointment, only 9 patients (43 percent)
received a timely appointment. One patient received his appointment one day late; seven
more patients received their appointments between 9 and 83 days late. For the final four
patients, there was no evidence the appointments ever occurred (MIT 1.005).
Only 16 of 28 sampled patients who received a routine or high-priority specialty service
(57 percent) also received a timely follow-up appointment with a provider at SATF. Seven
patients’ high-priority specialty follow-up appointments were 10 to 60 days late. Three
patients’ routine specialty follow-up appointments were 5 to 14 days late; and for two
patients, there was no evidence found that their routine specialty follow-up appointments
occurred (MIT 1.008).
Among 25 patients sampled who transferred into SATF from other institutions and were
referred to a provider based on nursing staff’s initial health care screening, only 16
(64 percent) were seen timely. Six patients received their provider appointments from 3 to
17 days late; two patients were seen 49 and 159 days late; for one final patient, there was no
evidence to indicate he was ever seen (MIT 1.002).
The following tests earned adequate scores:
Among 25 sampled patients who were discharged from a community hospital, 21
(84 percent) received a timely PCP follow-up appointment upon returning to SATF. One
patient received his follow-up appointment three days late. For three other patients, there
was no evidence found that the required follow-up appointments occurred (MIT 1.007).
Inmates had access to health care services request forms at five of six housing units
inspected (83 percent). One inspected housing unit did not have a supply of the forms
available for patients’ use (MIT 1.101).
Of the ten sampled patients who were referred to and seen by a provider and for whom the
provider subsequently ordered a follow-up appointment, nine (90 percent) received their
follow-up appointments timely. One patient‘s appointment was 21 days late (MIT 1.006).
The institution performed in the proficient range in the following areas:
For 52 of the 54 sampled patients who submitted health care services request forms, nursing
staff completed a face-to-face encounter within one business day of reviewing the form (96
percent). For one patient, the nurse failed to complete the nursing assessment form, and for
the final patient, there was no evidence the face-to-face encounter ever occurred (MIT
1.004).
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Inspectors sampled 55 health care services request forms submitted by patients across all
facility clinics. Nursing staff reviewed 52 of the 55 service request forms on the same day
they were received (95 percent). There was no evidence found that two of the forms were
reviewed; on one final form, nursing staff did not annotate a date or time (MIT 1.003).
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2 — DIAGNOSTIC SERVICES
This indicator addresses several types of diagnostic services.
Case Review Rating:
Specifically, it addresses whether radiology and laboratory services
Adequate
were timely provided to patients, whether the primary care provider Compliance Score:
timely reviewed the results, and whether the results were Inadequate
communicated to the patient within the required time frames. In (54.9%)
addition, for pathology services, the OIG determines whether the
Overall Rating:
institution received a final pathology report and whether the provider Adequate
timely reviewed and communicated the pathology results to the
patient. The case reviews also factor in the appropriateness,
accuracy, and quality of the diagnostic test(s) ordered and the clinical response to the results.
For this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance testing resulting in an
inadequate score. The primary reason for the inadequate compliance score was that many reports
were not timely reviewed by providers and were not timely communicated to patients. However,
while case review also found this pattern, case review revealed that providers were aware of the
diagnostic results, and patient care was not hindered. The OIG inspection team considered both case
review and compliance testing results and concluded that the overall rating for the Diagnostic
Services indicator was adequate.
Case Review Results
The OIG clinicians reviewed 189 diagnostic-related events and found nine deficiencies, with two
significant. Of the nine deficiencies, seven were related to health information management and two
were related to delayed tests or tests that were not performed.
Test Completion
Most diagnostic testing was scheduled and conducted in a timely manner as ordered. There were
two significant deficiencies, but there was no pattern identified that would indicate a systemic
problem in health care delivery.
In case 8, the provider ordered laboratory tests for the next morning to monitor the patient’s
response to antibiotics. However, the laboratory tests were not done.
In case 14, the provider ordered a hand X-ray for the next morning, but the test was not
performed until five days later. This resulted in a delay in treating a bone fracture, and could
have resulted in the bones healing in the wrong position (malunion).
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Health Information Management
There were seven minor deficiencies in health information management of diagnostic results.
Diagnostic laboratory test results were retrieved and forwarded to the medical providers for their
review within the appropriate time frames. Laboratory test results then were scanned into the
electronic medical records in a timely fashion. The providers were aware of the X-ray reports, as
evidenced by their progress notes, as well as the signed Notification of Diagnostic Test Results
(CDCR Form 7393), which communicates the results to the patient.
Clinician Onsite Inspection
SATF was able to properly process same-day, urgent, or “stat” (immediate) in-house diagnostic
testing, including blood draws, electrocardiograms (EKGs), and X-rays. There was no pattern of
delays or other problems identified in this indicator.
Case Review Conclusion
In general, SATF performed well with regard to diagnostic services, and this indicator was rated
adequate.
Compliance Testing Results
The institution received an inadequate compliance score of 54.9 percent in the Diagnostic Services
indicator, which encompasses radiology, laboratory, and pathology services. For clarity, each type
of diagnostic service is discussed separately below:
Radiology Services
Radiology services were timely performed for eight of ten patients sampled (80 percent);
two patients received their services one and seven days late (MIT 2.001). SATF providers
did not evidence timely review of any of the corresponding diagnostic service reports
sampled by initialing and dating the report as CCHCS policy requires, scoring zero on this
test (MIT 2.002). Providers then timely communicated the test results to only three of the ten
patients (30 percent). Six patients’ results were communicated from one to seven days late,
and one final patient’s radiology result was communicated 16 days late (MIT 2.003).
Laboratory Services
The OIG tested ten ordered laboratory service samples. Inspectors were not able to find
evidence of a particular order date for two of the original ten samples, so those two samples
were not applicable for this specific test. Of the eight samples that were applicable, seven
patients (88 percent) received their provider-ordered laboratory services timely; one of the
services, which was ultimately refused by the patient, was offered three days late
(MIT 2.004). Of the ten original laboratory service samples tested, there were nine
laboratory services actually provided. The institution’s providers reviewed all nine of the
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resulting laboratory services reports within the required time frame (MIT 2.005). Finally,
providers timely communicated the laboratory results to only five of the nine patients who
received a laboratory service (56 percent); two patients’ results were communicated one and
three days late; one patient’s result was communicated 56 days late; for one final patient,
there was no evidence found that the report was communicated at all (MIT 2.006).
Pathology Services
SATF received seven of the ten (70 percent) sampled final pathology reports timely. Three
reports were received 18, 38, and 56 days late (MIT 2.007). With regard to providers’
review and communication of the pathology results, SATF scored poorly. Providers
evidenced their review by initialing and dating six of the ten reports (60 percent). One report
was reviewed six days late, and three other reports had no evidence of review (MIT 2.008).
Further, providers communicated pathology results timely to only one of nine applicable
patients (11 percent). Six patients were notified of their pathology results from three to eight
days late, and two patients never received their pathology results (MIT 2.009).
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3 — EMERGENCY SERVICES
An emergency medical response system is essential to providing
Case Review Rating:
effective and timely emergency medical response, assessment,
Adequate
treatment, and transportation 24 hours per day. Provision of
Compliance Score:
urgent/emergent care is based on a patient’s emergency situation, Not Applicable
clinical condition, and need for a higher level of care. The OIG
Overall Rating:
reviews emergency response services including first aid, basic life
Adequate
support (BLS), and advanced cardiac life support (ACLS) consistent
with the American Heart Association guidelines for cardiopulmonary
resuscitation (CPR) and emergency cardiovascular care, and the provision of services by
knowledgeable staff appropriate to each individual’s training, certification, and authorized scope of
practice.
The OIG evaluates this quality indicator entirely through clinicians’ reviews of case files and
conducts no separate compliance testing element.
Case Review Results
The OIG clinicians reviewed 22 urgent or emergent events and found 19 deficiencies, with 3 of
these deficiencies considered significant.
CPR Response
The CPR response was good. There were no significant deficiencies identified.
Provider Performance
Provider performance in the TTA was satisfactory. The OIG identified three provider deficiencies,
of which two were significant:
In case 20, the provider failed to give medications to reduce critically high blood pressure
before transferring the patient to an outside emergency department.
In case 22, the provider failed to timely manage a patient with unstable breathing and chest
discomfort. The provider waited 75 minutes before ordering an EKG, and did not decide to
send the patient to the hospital for a possible heart attack until more than two hours after he
presented with chest discomfort. The OIG clinicians considered this an adverse event.
Nursing Documentation and Performance
Nursing documentation was generally appropriate and timely. The first responder data sheets
identified the condition of the patients and the emergent care provided by the staff. The majority of
the patients were transferred to the TTA without delays.
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In general, the nursing care provided during emergency medical responses was sufficient. There
was only one significant deficiency:
In case 22, the nurse did not call 9-1-1 when the patient presented to the TTA with chest
tightness and unstable breathing. Instead, the nurse called the provider and waited for the
provider to respond. It took four hours before the patient was transferred to an outside
emergency department for a possible heart attack. Furthermore, the nurse did not record the
treatments ordered by the provider, the time that the provider was notified, or the time that
the initial vital signs were taken. The OIG clinicians considered this an adverse event.
Emergency Medical Response Review Committee
The OIG clinicians evaluated seven Emergency Medical Response Review Committee (EMRRC)
reviews of incidents in which patients were sent emergently to a community hospital. The EMRRC
successfully identified deficiencies and documented quality improvement processes that included
education and training.
Clinician Onsite Inspection
During the OIG onsite inspection, an emergency occurred; a patient was in respiratory distress. The
SATF emergency response was observed to be timely and appropriate.
The TTA had three exam rooms, each with two beds. The OIG interviewed TTA staff and the
supervisor. The TTA RN had worked in the TTA for four months, and felt that staff morale was
positive and that support from nursing administrators was good. The TTA supervisor held daily
meetings with all TTA staff and described their current quality improvement projects.
Case Review Conclusion
The OIG rated the Emergency Services indicator adequate.
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4 — HEALTHINFORMATION MANAGEMENT
Health information management is a crucial link in the delivery of
Case Review Rating:
medical care. Medical personnel require accurate information in
Adequate
order to make sound judgments and decisions. This indicator
Compliance Score:
examines whether the institution adequately manages its health care Inadequate
information. This includes determining whether the information is (60.7%)
correctly labeled and organized and available in the electronic
Overall Rating:
medical records; whether various medical records (internal and Inadequate
external, e.g., hospital and specialty reports and progress notes) are
obtained and scanned timely into patients’ electronic medical records;
whether records routed to clinicians include legible signatures or stamps; and whether hospital
discharge reports include key elements and are timely reviewed by providers.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance testing resulting in an
inadequate score. The OIG’s internal review process considered those factors that led to both results
and rated this indicator inadequate. The compliance testing for this indicator provides a quantitative
measure of the scanning of records and proper labeling and filing of electronic medical record
documents by health information management staff. Compliance testing also revealed a notable
issue with provider review of hospital discharge documents. As a result of these deficiencies, the
overall score was determined to be inadequate.
During the OIG’s testing period, SATF had not yet converted to the new Electronic Health Record
System (EHRS); therefore, all testing occurred in the electronic Unit Health Record (eUHR)
system.
Case Review Results
The OIG clinicians reviewed 1,531 events and found 61 deficiencies related to health information
management, 3 of which were significant.
Inter-Departmental Transmission
There were no deficiencies identified in this area.
Hospital Records
The OIG reviewed 39 hospital events and identified seven minor deficiencies consisting of health
information management staff scanning the reports without provider review and signature.
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Specialty Services
The institution timely retrieved and scanned most specialty services reports. The OIG found six
specialty services reports scanned without the required provider review and signature. While this
did not hinder patient care in most events, it did delay important care in one case (case 9), which
was a significant deficiency. This is also discussed in the Specialty Services indicator.
In case 9, a cardiology consultation report was scanned into the electronic medical record
without being reviewed or signed by the medical provider. As the provider was unaware of
the recommendations, the provider did not promptly follow the recommendations. This
contributed to a delay in performing the needed heart test (cardiac catheterization).
Diagnostic Reports
SATF performed well in this area with only four minor deficiencies. Performance in this area is also
discussed in the Diagnostic Services indicator.
Urgent/Emergent Records
SATF performed well obtaining and scanning emergency care records. There were 49 events
reviewed and nine minor deficiencies identified. Five involved missing or misfiled reports, and four
involved reports scanned twice.
Scanning Performance
The OIG found that SATF scanned reports into the electronic medical record without a providers’
review or signature. This is further discussed in the Diagnostic Services indicator.
Legibility
Illegible notes pose a significant medical risk to patients, especially when other providers need to
review a patient’s records or when a patient is transferred to a different health care team or to
another institution. Many reports were dictated and transcribed and, therefore, legible. Occasional
handwritten notes were illegible, or there was no signature stamp for identification.
Case Review Conclusion
SATF timely retrieved and scanned documents into patient electronic medical records. Many
documents were scanned prior to review and signature by providers. This was also found in Cycle
4.The OIG case review clinicians rated the Health Information Management indicator adequate.
Compliance Testing Results
The institution earned an inadequate compliance score of 60.7 percent in the Health Information
Management indicator. The following areas showed room for improvement:
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The institution scored zero in its labeling and filing of documents scanned into patients’
electronic medical records. The errors included mislabeled and misfiled documents.
Inspectors found 18 mislabeled documents and identified 6 documents that were missing.
For this test, once the OIG identifies 24 mislabeled or misfiled documents, the maximum
points are lost and the resulting score is zero (MIT 4.006).
Among 25 sampled patients admitted to a community hospital and then returned to SATF,
only 9 (36 percent) had a complete hospital discharge report that was timely reviewed by a
primary care provider. For five patients, no hospital discharge record was found; for two
patients, the hospital discharge record lacked key elements; for four patients, the provider
review was two to three days late; and for five final patients, there was no evidence that a
provider reviewed the hospital discharge record at all (MIT 4.007).
Medication Administration Records (MARs) staff at SATF did not always timely scan
medication administration records into patients’ electronic medical records. Only 13 of 20
sampled documents (65 percent) were scanned within the required time frames. Seven
MARs were scanned from one to 14 days late (MIT 4.005).
Two tests earned scores in the adequate range:
SATF’s medical records staff timely scanned 17 of the 20 sampled specialty service
consultant reports into patients’ electronic medical records (85 percent). One specialty report
was scanned one day late, and two others were not found in the electronic medical records
(MIT 4.003).
The institution timely scanned 15 of the 18 sampled community hospital discharge reports or
treatment records into patients’ electronic medical records (83 percent); three reports were
untimely by one, 3, and 11 days (MIT 4.004).
The institution earned one proficient score in this indicator:
The institution timely scanned 19 of 20 sampled non-dictated progress notes, initial health
screening forms, and requests for health care services into the electronic medical records
(95 percent). One initial health screening form was scanned 33 days late (MIT 4.001).
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5 — HEALTH CARE ENVIRONMENT
This indicator addresses the general operational aspects of the
Case Review Rating:
institution’s clinics, including certain elements of infection control Not Applicable
and sanitation, medical supplies and equipment management, the Compliance Score:
availability of both auditory and visual privacy for patient visits, and Inadequate
(69.4%)
the sufficiency of facility infrastructure to conduct comprehensive
medical examinations. Rating of this component is based entirely on Overall Rating:
the compliance testing results from the visual observations inspectors Inadequate
make at the institution during their onsite visit.
This indicator is evaluated entirely by compliance testing. There is no case review portion.
Compliance Testing Results
The institution received an inadequate compliance score of 69.4 percent in the Health Care
Environment indicator, with areas needing improvement as follows:
OIG inspectors observed clinicians’ encounters with patients in 12 clinics. Clinicians
followed good hand hygiene practices in only five clinics (42 percent). At seven clinic
locations, clinicians failed to wash their hands before or after patient contact or before
putting on gloves (MIT 5.104).
Only 5 of 12 clinic locations (42 percent) met compliance requirements for essential core
medical equipment and supplies. The remaining seven clinics were missing one or more
functional pieces of properly calibrated core equipment or other medical supplies necessary
to conduct a comprehensive exam. The missing items consisted of an appropriate Snellen
eye exam chart distance marker, and tongue depressors. In addition, a nebulization unit and
oto-ophthalmoscope did not have calibration stickers. The oto-ophthalmoscopes in two
clinics were broken. Another clinic’s oto-ophthalmoscope was missing a calibration sticker,
and one other clinic’s nebulization unit was missing a
calibration sticker (MIT 5.108).
Only 6 of 12 clinic exam rooms observed (50 percent) had
appropriate space, configuration, supplies, and equipment to
allow clinicians to perform a proper clinical examination.
Three clinics had confidential records that were unsecured,
visible, and easily accessible to inmate-porters. In another two
clinics, patient examination was conducted without providing
visual and reasonable auditory privacy. One clinic had a torn
vinyl cover on the exam table (Figure 1), and another clinic
Figure 1: Exam Table with
torn Vinyl
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had cluttered exam room supplies (Figure 2) (MIT 5.110).
Regarding proper protocols to mitigate exposure to
blood-borne pathogens and contaminated waste, only 7 of 12
clinics were compliant. SATF received a score of 58 percent
on this test because two clinics had one or more exam rooms
that lacked a sharps container. In another two clinics, sharps
containers were not secured to fixed objects (Figure 3), and in
another clinic, a sharps container was found overfilled at the
time of inspection (MIT 5.105).
Inspectors examined emergency response bags (EMRBs) to
Figure 2: Cluttered exam
determine if they were inspected daily and inventoried
room supplies
monthly and whether they contained all essential items. They
were compliant in 7 of the 11 clinical locations where they
were stored (64 percent). One or more of the following
deficiencies emerged at four locations: there was no
documentation indicating that an inventory of the EMRB had
been completed in the previous 30 days; and an EMRB log
was missing one entry evidencing staff verified the bag’s
compartments were sealed and intact (MIT 5.111).
The following tests scored in the adequate range:
Out of 12 clinic locations inspected, 10 (83 percent) had
operable sinks and sufficient quantities of hand hygiene
Figure 3: Sharps container
supplies in the exam areas. Two separate clinics’ inmate
not secured to a fixed object
restrooms did not have sufficient quantities of hygiene
supplies, such as antiseptic soap and disposable hand towels (MIT 5.103).
Clinical health care staff at 9 of the 12 applicable clinics (75 percent) ensured that reusable
invasive and non-invasive medical equipment was properly sterilized or disinfected. In two
clinics, nursing staff failed to describe the process to disinfect the exam table prior to the
start of the shift. In another clinic, previously sterilized invasive medical equipment
packaging was found torn, compromising the sterility of the equipment (MIT 5.102).
Inspectors found that 9 of the 12 clinics (75 percent) followed adequate medical supply
storage and management protocols. Medical supplies at two clinics were not orderly or
clearly identifiable, and in one clinic, staff’s personal items were stored in the same area as
medical supplies. In another clinic, there was no inventory replenishment system in place to
ensure that medical supplies were stocked and restocked on a regular basis. Several medical
supplies were found stored beyond the manufacturers guidelines (MIT 5.107).
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Clinic common areas at 9 of the 12 clinics (75 percent) had environments conducive to
providing medical services. Three clinics lacked reasonable auditory privacy in the vital sign
stations (MIT 5.109).
Two tests earned SATF proficient scores in this indicator:
All 12 clinics were appropriately disinfected, cleaned, and sanitary. More specifically, in all
clinics inspectors observed areas that were clean and not visibly dusty or dirty. In addition,
cleaning logs were present and completed, indicating cleaning crews regularly cleaned the
clinic (MIT 5.101).
The non-clinic bulk medical supply storage areas met the supply management process and
support needs of the medical health care program, earning SATF a score of 100 percent on
this test (MIT 5.106).
Non-Scored Results
The OIG gathered information to determine if the institution’s physical infrastructure was
maintained in a manner that supported health care management’s ability to provide timely or
adequate health care. The OIG did not score this question. When OIG inspectors interviewed
health care managers, they did not identify any significant concerns. At the time of the
OIG’s medical inspection, SATF had several significant infrastructure projects underway,
which consisted of increasing clinic space in primary care clinics, expanding medication
distribution areas, and improving specialty care clinics and health records space. These
projects started in the summer of 2015, and the institution estimated that these projects
would be completed by the spring of 2018 (MIT 5.999).
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6 — INTER- AND INTRA-SYSTEM TRANSFERS
This indicator focuses on the management of patients’ medical needs
Case Review Rating:
and continuity of patient care during the inter- and intra-system Adequate
transfer process. The patients reviewed for this indicator include Compliance Score:
those received from, as well as those transferring out to, other CDCR Adequate
(80.7%)
institutions. The OIG review includes evaluation of the institution’s
ability to provide and document health screening assessments, Overall Rating:
initiation of relevant referrals based on patient needs, and the Adequate
continuity of medication delivery to patients arriving from another
institution. For those patients, the OIG clinicians also review the timely completion of pending
health appointments, tests, and requests for specialty services. For patients who transfer out of the
institution, the OIG evaluates the ability of the institution to document transfer information that
includes pre-existing health conditions, pending appointments, tests and requests for specialty
services, medication transfer packages, and medication administration prior to transfer. The OIG
clinicians also evaluate the care provided to patients returning to the institution from an outside
hospital and check to ensure appropriate implementation of the hospital assessment and treatment
plans.
Case Review Results
The OIG clinicians reviewed 52 inter- and intra-system transfer events, including information from
both the sending and receiving institutions. These included 21 transfers out for higher levels of care
at community hospitals, 20 of which resulted in a return transfer back to the institution. One patient
died at the hospital (case 22). There were 12 deficiencies, one of which was significant.
Transfers In and Out
The OIG clinicians reviewed 19 transfer-in events. There were three minor deficiencies. Among
eight events regarding patients transferring out of the institution, there were two minor deficiencies
with nursing documentation.
Hospitalizations
Patients returning from hospitalizations are some of the highest-risk encounters due to two factors.
First, these patients are generally hospitalized for a severe illness or injury. Second, they are at risk
due to potential lapses in care that can occur during any transfer. The OIG clinicians reviewed 20
hospitalizations and outside emergency room events and the patients’ subsequent transfers back to
SATF. Among these events, six minor deficiencies were identified, four of which consisted of
health information management staff scanning discharge summaries into patients’ electronic
medical records prior to their being reviewed by the provider. There were two significant
deficiencies:
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In case 22, the patient returned from the hospital with a discharge diagnosis of pulmonary
emboli (blood clots in the lung). The nurse missed the diagnosis on the hospital discharge
summary and, therefore, did not report the diagnosis to the on-call physician upon the
patient’s return to SATF. That physician and subsequent physicians failed to review the
hospital discharge summary. This led to a delay in treatment of the patient’s blood clots with
blood-thinning medication. This case is further discussed in the Quality of Provider
Performance and Specialized Medical Housing indicators.
Case Review Conclusion
SATF performed well with regard to Inter- and Intra-System Transfers, and the case review rating
was adequate.
Compliance Testing Results
The institution obtained an adequate compliance score of 80.7 percent in the Inter- and
Intra-System Transfers indicator, with two tests earning proficient scores of 100 percent:
Nursing staff timely completed the assessment and disposition sections of the screening
form for all 24 applicable patients sampled (MIT 6.002).
The OIG inspected the transfer packages of two patients who were transferring out of the
facility to determine whether the packages included required medications and support
documentation. All transfer packages were compliant (MIT 6.101).
One test earned an adequate score:
The OIG tested 24 applicable patients who transferred into SATF from other CDCR
institutions to determine whether they received a complete initial health screening
assessment from nursing staff on the day of their arrival; 20 of the assessments (83 percent)
were complete and timely. For two patients, required elements of the assessment were not
performed by nursing staff; for another patient, the assessment was not found in the
electronic medical record; for one final assessment, compliance could not be ascertained
because the encounter date was incorrect (MIT 6.001).
The following tests showed areas for needed improvement:
Among 18 applicable sampled patients who transferred into SATF, 9 (50 percent) received
their medication without interruption. Nine patients incurred medication interruptions of one
or more dosing intervals upon arrival (MIT 6.003).
Inspectors sampled 20 patients who transferred out of SATF to other CDCR institutions to
determine whether nursing staff identified scheduled specialty service appointments on the
patients’ health care transfer forms. Nursing staff correctly listed the pending specialty
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service appointments for 14 of 20 patients (70 percent). On six health care transfer forms
sampled, staff failed to note the patients’ pending specialty service appointments
(MIT 6.004).
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7 — PHARMACY AND MEDICATION MANAGEMENT
This indicator is an evaluation of the institution’s ability to provide
Case Review Rating:
appropriate pharmaceutical administration and security Adequate
management, encompassing the process from the written Compliance Score:
prescription to the administration of the medication. By combining Inadequate
(72.7%)
both a quantitative compliance test with case review analysis, this
assessment identifies issues in various stages of the medication Overall Rating:
management process, including ordering and prescribing, Inadequate
transcribing and verifying, dispensing and delivering,
administering, and documenting and reporting. Because effective medication management is
affected by numerous entities across various departments, this assessment considers internal review
and approval processes, pharmacy, nursing, health information systems, custody processes, and
actions taken by the prescriber, staff, and patient.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating, and the compliance review resulting in an
inadequate score. The OIG’s internal review process considered those factors that led to both scores
and ultimately rated this indicator inadequate. While case review focused on medication
administration, the compliance testing was a more robust assessment of medication administration
and pharmacy protocols combined with onsite observations of medication and pharmacy operations.
As a result, the compliance score of inadequate was deemed appropriate for the indicator rating.
Case Review Results
The OIG clinicians evaluated 81 events related to medications and found only 6 minor deficiencies
and one significant deficiency. The case reviews revealed no pattern of deficiencies, and the case
review rating of the Pharmacy and Medication Management indicator was adequate.
Medication Continuity
SATF performed well with medication continuity. Five cases had deficiencies in the form of delays
in the delivery of medication to the patient in cases 1, 5, 15, 18, and the following:
In case 22, some medication administration records for an injected blood-thinning
medication was not in the electronic medical record. This deficiency is also discussed in the
Health Information Management indicator.
Medication Administration
There was only one significant deficiency identified in medication administration by nursing staff:
In case 22, SATF nurses did not administer a critical blood-thinning medication that was
needed to treat the patient’s blood clots that had travelled into his lungs.
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Pharmacy Errors
The OIG clinicians did not identify any significant pharmacy deficiencies.
Clinician Onsite Inspection
OIG clinicians interviewed medication nurses at several clinics during the onsite inspection visit.
The medication nurses were temporarily relocated from Yard A to the gym due to construction on
site. Nurses stated that the gym area was well ventilated, and despite the high temperatures outside,
there were no problems with medications exposed to heat. Medication management and storage
areas in the gym were considered adequate. On Yard F, the construction of the medication room
was completed. The room was spacious, clean, and capable of storing supplies and medical durable
equipment. The office technician also shared a space in the room and did not interfere with the daily
tasks of the medication administration team. The nurses on both yards reported a consistent practice
of reporting medication errors, documenting, and reporting missed doses or “no-shows.” There were
no barriers between medication nurses and their supervisors. Nurses and psychiatric technicians
from other yards also reported that supervisors were easily accessible by staff.
Case Review Conclusion
SATF performed well with regard to the Pharmacy and Medication Management indicator, and the
case review rating was adequate.
Compliance Testing Results
The institution received an inadequate compliance score of 72.7 percent in the Pharmacy and
Medication Management indicator. For discussion purposes below, this indicator is divided into
three sub-indicators: medication administration, observed medication practices and storage controls,
and pharmacy protocols.
Medication Administration
In this sub-indicator, the institution received an inadequate score of 74.6 percent. Room for
improvement was evident in the following areas:
SATF timely provided hospital discharge medications to 11 of 23 applicable patients
sampled (48 percent). Nursing staff provided discharge medications from one to ten days
late for six patients; two other patients each missed two medication doses. For three patients,
there was no clear evidence found in the electronic medical record that their medication was
either received or refused. For one final patient, there was a critical medication order that
was not carried out (MIT 7.003).
Nursing staff administered medications without interruption to three of five patients who
were en route from one institution to another and had a temporary layover at SATF
(60 percent). Two patients each missed one dosage of their ordered medication (MIT 7.006).
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The following tests earned adequate scores:
Among 21 patients sampled, 17 timely received chronic care medications (81 percent).
There was no evidence one patient received one dose of a critical medication; three other
patients did not receive their keep-on-person (KOP) medications at ordered intervals
(MIT 7.001).
Of the 25 sampled patients at SATF who had transferred from one housing unit to another,
21 (84 percent) received their prescribed medications without interruption. Four patients did
not receive one or more doses of their medications at the next dosing interval after the
transfer occurred (MIT 7.005).
One test in this sub-indicator earned a proficient score of 100 percent:
All 25 patients sampled at SATF received their newly ordered medication in a timely
manner (MIT 7.002).
Observed Medication Practices and Storage Controls
In this sub-indicator, the institution received an inadequate score of 50.3 percent. All but one test in
this sub-indicator scored in the inadequate range, as follows:
The institution employed adequate security controls over narcotic medications in 2 of the 11
applicable clinic and medication line locations where narcotics were stored (18 percent). At
eight clinics, the narcotics logbook lacked evidence on multiple dates that a controlled
substance inventory was performed by two licensed nursing staff; at another clinic, the
narcotics logbook was missing a counter-signature for a disposal of controlled substance
(MIT 7.101).
SATF properly stored non-narcotic medications not requiring refrigeration in only two of
the ten applicable clinic and medication line storage locations (20 percent). In eight
locations, one or more of the following deficiencies were observed: the medication area
lacked a designated area for return-to-pharmacy medications; external and internal
medications were not properly separated when stored; medication rooms and cabinets were
unlocked; multi-use medication was not labeled with the date it was opened; and there was
no evidence that a monthly crash cart inventory was routinely practiced (MIT 7.102).
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Only three of the eight inspected medication
preparation and administration areas (38 percent)
demonstrated appropriate administrative controls and
protocols. At five different locations, one or more
deficiencies was observed: medication nurses did not
consistently verify patients’ identities with picture
identification; medication nurses did not always
ensure patients swallowed direct observation therapy
medications; a medication nurse was observed signing
a MAR prior to administering medications;
medication nurses did not appropriately administer
medication as ordered by the provider; and patients
waiting to receive their medications did not have
sufficient outdoor cover to protect them from heat or
inclement weather (Figure 4) (MIT 7.106).
Figure 4: Insufficient cover to protect
Nursing staff were compliant regarding proper hand
patients from inclement weather
hygiene and contamination control protocols at five of
eight inspected locations (63 percent). At three locations, not all nursing staff washed or
sanitized their hands when required, such as prior to putting on gloves, to re-gloving, and
when preparing medications (MIT 7.104).
Non-narcotic refrigerated medications were properly stored at 7 of 11 clinics and medication
line storage locations (64 percent). At four locations, one or more deficiencies were
identified: medication refrigerators were unlocked; medication refrigerators lacked a
designated area for return-to-pharmacy medications; and insulin medication vials were
found stored beyond the manufacturers’ guidelines (MIT 7.103).
One test in this sub-indicator received a proficient score of 100 percent:
Nursing staff at all eight of the inspected medication line locations employed appropriate
administrative controls and followed appropriate protocols during medication preparation
(MIT 7.105).
Pharmacy Protocols
In this sub-indicator, the institution received a proficient score of 97.6 percent, comprised of scores
received at the institution’s main pharmacy. Four of the five tests in this sub-indicator earned scores
of 100 percent, as follows:
In its main pharmacy, the institution followed general security, organization, and cleanliness
management protocols; properly stored and monitored non-narcotic medications that
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required refrigeration and those that did not; and maintained adequate controls over and
properly accounted for narcotic medications (MIT 7.107, 7.108, 7.109, and 7.110).
The institution’s pharmacist in charge (PIC) followed required protocols for 22 of the 25
medication error reports and monthly statistical reports reviewed (88 percent). For three
medication error reports, the PIC did not assign severity level of the medication error, and
did not document the date when the medication error follow-up review was completed
(MIT 7.111).
Non-Scored Tests
In addition to testing of reported medication errors, inspectors follow up on any significant
medication errors that were found during the compliance testing to determine whether the
errors were properly identified and reported. At SATF, there were no applicable medication
errors (MIT 7.998).
The OIG interviewed patients in isolation units to determine if they had immediate access to
their prescribed KOP rescue medications. All seven of the sampled patients had access to
their rescue medications (MIT 7.999).
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8 — PRENATAL AND POST-DELIVERY SERVICES
This indicator evaluates the institution’s capacity to provide timely Case Review Rating:
Not Applicable
and appropriate prenatal, delivery, and postnatal services to
Compliance Score:
pregnant patients. This includes the ordering and monitoring of
Not Applicable
indicated screening tests, follow-up visits, referrals to higher levels
of care, e.g., high-risk obstetrics clinic, when necessary, and Overall Rating:
Not Applicable
postnatal follow-up.
As SATF is a male-only institution, this indicator did not apply.
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9 — PREVENTIVE SERVICES
This indicator assesses whether various preventive medical
Case Review Rating:
services are offered or provided to patients. These include cancer
Not Applicable
screenings, tuberculosis screenings, and influenza and chronic Compliance Score:
care immunizations. This indicator also assesses whether certain Adequate
institutions take preventive actions to relocate patients identified (77.9%)
as being at higher risk for contracting coccidioidomycosis
Overall Rating:
(valley fever). Adequate
The OIG rates this indicator entirely through the compliance
testing component; the case review process does not include a separate qualitative analysis for this
indicator.
Compliance Testing Results
The institution performed in the adequate range in the Preventive Services indicator, with a
compliance score of 77.9 percent. Four tests earned proficient scores, as follows:
All 25 patients sampled timely received or were offered influenza vaccinations during the
most recent influenza season (MIT 9.004).
The OIG found that 29 of 30 patients sampled (97 percent) received timely annual
tuberculosis (TB) screenings. CCHCS policy requires that screenings occur in the patient’s
birth month; one patient’s screening occurred in the month following his birth month
(MIT 9.003).
SATF offered colorectal cancer screenings to 24 of 25 sampled patients subject to the annual
screening requirement (96 percent). For one patient, there was no electronic medical record
evidence either that health care staff offered a colorectal cancer screening within the
previous 12 months or that the patient had a normal colonoscopy within the last ten years
(MIT 9.005).
The OIG tested whether patients who suffered from a chronic care condition were offered
vaccinations for influenza, pneumococcal infection, and hepatitis. Among the 18 sampled
patients with applicable chronic conditions, 16 patients (89 percent) were timely offered the
vaccinations. There was no record that one patient received or refused the pneumococcal
immunization or the hepatitis A and B vaccinations within the last five years; for one other
patient, there was no evidence of receipt or refusal of the hepatitis A and B vaccinations
(MIT 9.008).
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The institution scored in the inadequate range on the following tests:
Among 12 sampled patients who received TB medications, the institution only properly
monitored four of them (33 percent). Eight patients required weekly or monthly monitoring,
but SATF clinicians did not monitor these patients in compliance with policy (MIT 9.002).
The OIG sampled 11 patients at high risk for contracting the coccidioidomycosis infection
(valley fever) who were medically restricted and ineligible to reside at SATF, to determine if
the patients were transferred out of the institution within 60 days from the time they were
initially determined ineligible. The institution was compliant for 7 of the 11 patients
sampled (64 percent). Four of the patients were not timely transferred (MIT 9.009):
o Two patients were transferred out of the institution 12 and 44 days late.
o One patient was transferred out of the institution 380 days late.
o One patient, who was initially identified on November 18, 2016, as ineligible to be
housed at SATF, was still there as of June 4, 2017. After a 60-day grace period for
the institution to transfer the patient out of the facility, the patient remained at SATF
more than 138 days.
SATF scored poorly for the timely administration of TB medications. The OIG examined
the health care records of all 12 patients who were on TB medications during the inspection
period, and only eight patients received all of their required medications (67 percent). Four
patients did not receive all of their ordered doses (MIT 9.001).
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10 — QUALITY OF NURSING PERFORMANCE
The Quality of Nursing Performance indicator is a qualitative
Case Review Rating:
evaluation of the institution’s nursing services. The evaluation is Adequate
completed entirely by OIG nursing clinicians within the case review Compliance Score:
process and does not have a score under the OIG compliance testing Not Applicable
component. Case reviews include face-to-face encounters and
Overall Rating:
indirect activities performed by nursing staff on behalf of the Adequate
patient. Review of nursing performance includes all nursing services
performed on site, such outpatient, inpatient, urgent/emergent,
inmate transfers, care coordination, and medication management. The key focus areas for evaluation
of nursing care include appropriateness and timeliness of patient triage and assessment,
identification and prioritization of health care needs, use of the nursing process to implement
interventions, and accurate, thorough, and legible documentation. Although nursing services
provided in specialized medical housing units are reported in the Specialized Medical Housing
indicator, and those provided in the TTA or related to emergency medical responses are reported in
the Emergency Services indicator, all areas of nursing services are summarized in this Quality of
Nursing Performance indicator.
Case Review Results
The OIG nursing clinicians reviewed 303 nursing encounters, of which 174 were outpatient nursing
encounters. Most were sick call requests, walk-in visits, and nursing follow-up visits. There were 52
deficiencies identified related to nursing care, two of which were significant. There were 31
deficiencies identified in the outpatient setting, none of which were significant. The OIG clinicians
rated the Quality of Nursing Performance at SATF adequate.
Nursing Assessment, Intervention, and Documentation
The majority of nursing assessments, interventions, and documentation were timely and
appropriate. In some cases, the SATF nurses did not adequately assess patients and did not
communicate abnormal findings to providers. However, in these cases, the deficiencies were minor
and unlikely to cause patient harm.
Sick Call
There were 90 outpatient sick calls reviewed. SATF nurses promptly triaged and scheduled patients
for assessments on the next business day for the majority of patients. Deficiencies found in the sick
call process included incomplete nursing assessments, insufficient recognition of potential urgency
of patients’ symptoms,, and failure to contact the provider for consultation. Additionally, in some
cases, nurses did not assess vital signs or document a plan of care for patients.
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Care Management
Care managers are defined by CCHCS as primary care RNs who develop, implement, and evaluate
patient care services and care plans for assigned patient panels. At SATF, RN care managers often
referred patients to providers for laboratory results follow-up, educated patients regarding
non-compliance with medication, and coordinated continuity of care for patients returning from
offsite specialty services or hospitalizations.
In case 15, the interventions completed by the RN care manager was proficient. The patient
in this case had returned from a cardiac procedure and had a lay-in accommodation to rest in
his cell for recovery purposes. The RN went to the patient’s cell to educate the patient on the
discontinuance of his blood-thinning medication, and retrieved the remaining KOP
medication from the patient. Since the patient was a lay in, he would not have gone to the
medication line, and would have continued taking the discontinued medication that was kept
in his housing area.
Urgent/Emergent
Nursing performance in the TTA and emergency medical response was good, although there was
one case with a significant deficiency (case 22). This case and deficiency is discussed in the
Emergency Services indicator.
Post Hospital Returns
Nurses’ performance for patients returning from the hospital was good. They made timely
assessments, documented notification to providers, and implemented hospital recommendations.
Among the 14 hospital return nursing encounters reviewed, nine minor and two significant
deficiencies were identified. These deficiencies are also summarized in the Inter- and Intra-System
Transfers and Access to Care indicators.
In case 2, a significant deficiency occurred when a follow-up specialty appointment was not
scheduled.
In case 22, a significant deficiency occurred in nursing performance regarding inadequate
review of the patient’s hospital discharge summary and not starting a medication to prevent
further blood clots.
Specialized Medical Housing
Nursing care in the CTC was good. There were 46 nursing encounters reviewed with various minor
deficiencies and two significant deficiencies. There were no specific patterns of deficiencies.
Nursing assessments were complete and thorough. Medication and treatment refusals and changes
in patient conditions were documented and reported to the provider promptly. Case review findings
and deficiencies are summarized in the Specialized Medical Housing indicator.
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Transfers
The OIG clinicians reviewed 12 nursing encounters involving transferring patients. The nursing
performance in this area was sufficient. Patients who arrived at the institution were assessed
appropriately and referred to the primary care team as required. Transfers out were also
appropriately completed. Performance in this area is also discussed in the Inter- and Intra-System
Transfers indicator.
Offsite Specialty Services Returns
There were 24 reviewed nursing encounters for patients returning from offsite specialty service
appointments. The TTA nurses assessed patients appropriately, reviewed the consultation
recommendations, and contacted the provider when necessary. Among the 17 deficiencies found in
all of specialty services, only two minor ones concerned nursing care. Performance in this area is
further discussed in the Specialty Services indicator.
Medication Administration
The SATF nurses performed well in this area. There were no significant deficiencies identified in
this process. Performance in this area is discussed in the Pharmacy and Medication Management
indicator.
Clinician Onsite Inspection
Upon the OIG clinicians’ arrival at SATF, they were informed that many clinical staff were
scheduled for education and training on the new electronic health record system (EHRS) during the
week of the medical inspection, that current staffing in various clinics might be affected, and that
certain staff may not be available for interviews. The shortage of staff was observed in the CTC and
in Yard F, where there was a delay in the usual time for starting the morning huddle.
The OIG clinicians visited various clinical departments, units, and outpatient clinics. Construction
was in progress on several housing yards. On Yard A, the clinic primary care provider, RN, and
office technician had been relocated to the freestanding dialysis building, and medication nurses had
been relocated to the gym. Although transportation of the patients to the relocation areas was
required, the scheduled clinic services occurred as planned, and patients rarely refused their clinical
appointments. The OIG clinicians attended morning huddles in the CTC and outpatient yards. In the
CTC, all medical staff was present with the exception of the supervising RN. There were no patient
appointment backlogs in the short term restricted housing unit (STRH). Implementation of a
tracking log in the STRH ensured that all provider and nurse follow-up appointments and referrals
were scheduled, and that patients were seen timely.
The OIG clinicians also interviewed the chief nursing executive (CNE), various supervisors, nurses
in specialty services, TTA nurses, and the psychiatric technicians and nurses in the medication
administration areas. Nursing supervisors were familiar with each staff member’s role and
responsibilities. Nursing staff generally felt the morale at SATF was positive, and that supervisory
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response and support was available. The CNE was aware of the need to improve the nursing care
plan documentation and had proactively obtained training materials for the staff.
Case Review Conclusion
The OIG clinicians rated the Quality of Nursing Performance indicator adequate.
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Office of the Inspector General State of California
11 — QUALITY OF PROVIDER PERFORMANCE
In this indicator, the OIG physicians provide a qualitative evaluation
Case Review Rating:
of the adequacy of provider care at the institution. Appropriate
Adequate
evaluation, diagnosis, and management plans are reviewed for
Compliance Score:
programs including, but not limited to, nursing sick call, chronic Not Applicable
care programs, TTA, specialized medical housing, and specialty
Overall Rating:
services. The assessment of provider care is performed entirely by
Adequate
OIG physicians. There is no compliance testing component
associated with this quality indicator.
Case Review Results
The OIG clinicians reviewed 429 medical provider encounters and identified 97 deficiencies related
to provider performance, 17 of which were significant. The OIG performed 25 detailed case reviews
and rated 21 adequate and 4 inadequate. The OIG clinicians rated this indicator adequate.
Assessment and Decision-Making
In most cases, providers made satisfactory assessments and sound decisions. In some cases, the
providers demonstrated proficient care:
In case 15, the provider, with the patient’s permission, contacted the patient’s family before
surgery to discuss a complex heart procedure.
In cases 15 and 16, the providers performed focused medication reviews to evaluate the
necessity of each of the many medications currently used by the patients (polypharmacy
review).
In case 16, the patient required many offsite eye consultation procedures and follow-up
visits. The provider was able to coordinate all of the many visits, often daily, without any
lapses in care.
However, the OIG also found some significant errors in assessment and decision-making. The
following deficiencies were in outpatient management. Deficiencies that occurred in the CTC are
discussed in Specialized Medical Housing indicator.
In case 6, the provider failed to perform timely follow-up for a patient with uncontrolled
hypertension. Prolonged hypertension increased the risk of permanent damage to various
organs, including the heart, brain, and kidneys. In addition, the provider did not order
appropriate laboratory monitoring after adjusting the patient’s blood pressure medications.
Not testing for abnormal electrolyte levels could have led to serious cardiac rhythm
disturbances and even, possibly, sudden death.
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Also in case 6, during other encounters, the provider made infrequent blood pressure
medication adjustments over seven months for a patient at high risk for heart disease and
stroke. The patient died suddenly, and it is possible that some of the provider errors could
have contributed to his death.
In case 11, the provider failed to fully assess a patient with extremely poor vision. The
provider should have performed a basic visual acuity test. In addition, the provider did not
provide disability accommodations.
In case 14, the provider failed to arrange for appropriate and timely follow-up for a patient
with a fractured hand.
In case 22, the provider failed to fully assess and manage a patient with a one-week
respiratory illness who continued to cough up blood.
In case 24, the provider inappropriately delayed a surgical referral for an eyelid cancer
removal.
Specialized Medical Housing
This is more fully discussed in the Specialized Medical Housing indicator. While the provider
performance here showed improvement from Cycle 4, this area continued to be the weakest area for
providers at SATF. Nine of the significant deficiencies were in specialized medical housing.
Emergency Care
The OIG reviewed 26 emergency or urgent TTA encounters. There were three deficiencies, two of
which were significant:
In case 20, the provider appropriately sent the patient with a dangerously high blood
pressure (220/123) to an outside emergency department. However, the provider failed to
treat the patient’s blood pressure with medications before sending the patient out.
In case 22, the patient had chest pain and difficulty breathing. The provider never came to
see the patient and waited 75 minutes before ordering an EKG. The patient had a possible
heart attack, but the provider did not decide to send the patient to the hospital until more
than two hours after the patient developed symptoms. The provider did not come in to assess
the patient in the TTA.
Chronic Care
Providers generally provided adequate chronic care. However, some patients with high blood
pressure were not appropriately managed, as described above. Most anticoagulation patients also
received adequate care, with the exception of the following patient:
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In case 9, multiple providers failed to recognize a gross error in a warfarin (blood-thinning
medication) dose. This led to a delay in properly adjusting the medication, and the patient
was at risk for developing blood clots. Fortunately, no harm came to the patient due to this
error.
Specialty Services
The OIG reviewed 150 specialty services events. In general, the SATF providers did well
facilitating this medical care. There were two minor deficiencies, both of which were a result of the
provider delaying or conducting an incomplete review of the specialist recommendations. These are
also discussed in the Specialty Services indicator. One encounter showed excellent provider care:
In case 17, the provider made a prompt telephone call to an infectious disease consultant to
discuss an unexpected change in antibiotic therapy and to obtain guidance for a challenging
patient who refused further therapy.
Clinician Onsite Inspection
The OIG inspectors learned from the leadership that SATF had three vacant provider positions over
the last six months, which contributed to a backlog. The vacancies had been filled recently.
The OIG discussed the deficiencies in CTC care with the chief medical executive (CME). These
deficiencies mainly occurred with the on-call providers, and many arose from incomplete record
review causing missed diagnoses or lapsed medications. The TTA and CTC had designated
providers. Since the providers worked on a four-day, ten-hour shift schedule, both the TTA and the
CTC required frequent provider changes to accommodate the regularly assigned providers’ days off.
In addition, the CTC required an on-call physician to cover weekends and holidays. These
schedules, while required for provider recruitment and retention, led to suboptimal continuity of
patient care because the on-call provider was not familiar with the patients’ needs.
Furthermore, per the CME, the on-call providers had been instructed to limit their interventions and
to make few changes to primary providers’ orders. The intention was to prevent inappropriate
changes by on-call providers who did not have a complete knowledge of the patient. However, this
may have also prevented the on-call providers from intervening for those patients with severe or
complex illness who required major day-to-day treatment changes.
SATF had a robust provider morning report where staff reviewed important changes that occurred
over the previous day. After the morning report, the providers went to their assigned clinics for the
multidisciplinary team huddles.
The morale among the providers was generally high, and all reported that the CME was supportive.
Other positive comments concerned the collegiality among group members, monthly group
presentations, and adequate radiology and pharmacy support. The providers mentioned that working
relationships with their nursing and custody colleagues was good.
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Case Review Conclusion
The care provided by SATF medical providers was adequate. Of the 25 cases reviewed, 21 were
adequate, and 4 were inadequate. Medical care in the CTC was adequate, but OIG clinicians
identified areas that need improvement.
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12 — RECEPTION CENTER ARRIVALS
This indicator focuses on the management of medical needs and
Case Review Rating:
continuity of care for patients arriving from outside the CDCR
Not Applicable
system. The OIG review includes evaluation of the ability of the Compliance Score:
institution to provide and document initial health screenings, Not Applicable
initial health assessments, continuity of medications, and
Overall Rating:
completion of required screening tests; address and provide Not Applicable
significant accommodations for disabilities and health care
appliance needs; and identify health care conditions needing
treatment and monitoring. The patients reviewed for reception
center cases are those received from non-CDCR facilities, such as county jails.
Because SATF did not have a reception center, this indicator did not apply.
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13 — SPECIALIZED MEDICAL HOUSING
This indicator addresses whether the institution follows appropriate
Case Review Rating:
policies and procedures when admitting patients to onsite inpatient
Adequate
facilities, including completion of timely nursing and provider
Compliance Score:
assessments. The chart review assesses all aspects of medical care Adequate
related to these housing units, including quality of provider and (85.0%)
nursing care. SATF’s specialized medical housing unit was a
Overall Rating:
correctional treatment center (CTC).
Adequate
Case Review Results
The CTC was a 38-bed unit. There were 18 designated beds for patients with medical care needs,
nine negative pressure rooms (rooms used to minimize the spread of airborne infections), and 20
beds for mental health patients. The OIG clinicians reviewed nine CTC admissions with 582 events.
There were 313 provider encounters and 46 nursing encounters. There were 71 deficiencies, 10 of
which were significant.
Provider Performance
SATF providers did well with most CTC encounters. There were many encounters reviewed, and
providers generally made good quality assessments and decisions, reviewed documents with
adequate depth, and performed admission history and physicals regularly. Provider care in the CTC
was sufficient, but OIG clinicians noted several areas for improvement, and there were many
significant deficiencies, particularly in case 22 (discussed below in detail). In addition, the
discharge summaries often lacked sufficient detail to ensure continuity of medical care when the
patients transferred to the outpatient clinics.
In case 7, the patient was in hospice care for end-stage heart disease. Despite the patient
having requested comfort measures only, the provider continued unnecessary medications
such as iron, which could have worsened the already present constipation. In addition, there
were inappropriate orders to withhold pain medication when the patient’s blood pressure
was low, which could have caused the patient unnecessary suffering.
Also in case 7, an unnecessary and uncomfortable enema was ordered when other, more
comfortable measures were possible.
In case 8, the patient had congestive heart failure. On a single day, two providers examining
the patient documented extremely discordant physical exam findings. This indicated a
flawed examination or documentation by one of the providers.
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In case 9, the patient’s warfarin (blood thinner) was mistakenly decreased to 10 percent of
the original dose. The error was not recognized by multiple providers. Fortunately, no harm
came to the patient, who required the blood thinner for the treatment of blood clots.
Five of the significant deficiencies were in case 22. This was a complex patient with end-stage heart
disease and multiple-organ failure. Most of his care was adequate, but the final weeks of care were
not adequately managed, and likely led to the patient’s untimely death:
The provider delayed sending the patient to a higher level of care when his condition was
unstable.
Multiple providers failed to recognize that the patient was not being treated for a blood clot
in the lung for which he had recently been hospitalized.
The providers failed to carefully review hospital discharge orders, and there was a delay in
the patient receiving the correct blood-thinning medication.
An initial history and physical exam (H&P) for the CTC admission was not done. Not only
was this a deviation from standard practice, but the H&P was especially necessary for this
complex patient.
In one encounter, the provider failed to adequately address potential serious heart and
gastrointestinal side effects of amitriptyline (chronic pain medication, also used for
depression).
Nursing Performance
Nursing performance in the CTC was generally good. In the majority of cases, nursing assessments
were timely and thorough, and the documentation addressed changes in patients’ conditions with
interventions. The patients who were admitted for end-of-life care received appropriate nursing
care, and refusals of medications and treatments were reported to providers. Nursing care plans
lacked specific interventions regarding changes in patients’ conditions, but these deficiencies were
mostly minor. There were eight nursing deficiencies related to monitoring and documentation.
There were three deficiencies identified in the category of health information management, all
consisting of missing documentation. Several nursing deficiencies, including one significant,
occurred in one case:
In case 22, the patient was diagnosed with heart failure, and the provider ordered daily fluid
restrictions. The nursing staff failed to implement the fluid restriction on two different
occasions, and the patient exceeded the daily fluid limit. This error placed the patient, whose
heart was already compromised, at risk of increased cardiac stress. The nursing staff also did
not adequately document specific interventions in the nursing care plan related to the
providers’ order of the fluid restriction.
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Health Information Management
Specific deficiencies identified in this category are explained in the Health Information
Management indicator.
Appointments and Scheduling
There were two deficiencies identified in this category, one of which was significant (case 17),
which is discussed in the Access to Care indicator.
Clinician Onsite Inspection
The CTC was not adequately staffed at the time of the clinicians’ onsite visit. The institution was
currently in the education and training process for the EHRS implementation, and the CTC staffing
assignment was affected on the day of the onsite inspection. In the case reviews, the OIG identified
deficiencies related to the missing documentation of the utilization management nurse. It was
discovered during the onsite visit that the utilization management nurse was unaware of the need to
review each CTC patient’s level of care on a monthly basis for the appropriateness of the continued
inpatient admission. The CNE acknowledged the deficits and communicated a plan to improve the
process with education and training for the staff.
The OIG discussed the deficiencies in CTC care with the chief medical executive (CME). While the
OIG found the care provided by the assigned provider to be adequate, the temporary providers’ care
was often problematic. As discussed in the Quality of Provider Performance indicator, these
deficiencies may have been caused by leadership’s instructions to limit covering provider
management, and to avoid making too many changes to primary providers’ orders. This culture may
have kept covering providers from fully reviewing or intervening for those patients with severe or
complex illness who required major day-to-day treatment changes.
Case Review Conclusion
The weakest provider performance at SATF was in the CTC, as was also the case in Cycle 4. While
Cycle 5 showed some improvement, more was still needed. The OIG recognized that two factors
contributed to the poor performance. The first was lack of continuity. While there was an assigned
provider, the provider was regularly scheduled three days off per week. This schedule frequently
required other providers to see the patients when the assigned provider was out. The covering
providers would often spend insufficient time reviewing the medical records of complex patients
because they were only providing care for a day or two. This led to missed diagnoses or lapsed
medications. The second factor contributing to the poor performance was the complexity of the
medical patients. While categorized as a “basic” medical institution, SATF still had many high-risk,
complex medical patients. Many CTC patients were temporarily housed from other institutions that
lacked CTC beds. Providers sometimes failed to take a careful enough approach to these medically
complex patients.
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Because CTC provider care was minimally sufficient and CTC nursing care was adequate, the OIG
rated the case review portion of Specialized Medical Housing indicator adequate.
Compliance Testing Results
The institution earned an adequate compliance score of 85.0 percent in the Specialized Medical
Housing indicator. The following tests received proficient scores of 100 percent:
For all ten patients sampled, nursing staff timely completed an initial health assessment on
the day the patient was admitted to the CTC (MIT 13.001).
When inspectors observed the working order of sampled call buttons in CTC patient rooms,
inspectors found all working properly. In addition, according to staff members interviewed,
custody officers and clinicians were able to expeditiously access patients’ locked rooms
when emergent events occurred (MIT 13.101).
Two tests in this indicator received inadequate scores, as follows:
Providers completed a history and physical (H&P) within 24 hours of admission to the CTC
for seven out of the ten patients sampled (70 percent). Two patients were evaluated one day
late; for one other patient’s admission, the provider did not document a time on the H&P so
its timeliness could not be ascertained (MIT 13.002).
The OIG tested whether providers completed their Subjective, Objective, Assessment, Plan,
and Education (SOAPE) notes at required three-day intervals for patients housed in the
CTC. Providers completed timely SOAPE notes for seven of ten sampled patients
(70 percent). Provider notes were one day late for two patients, and for one final patient, the
documentation on one SOAPE note was incomplete (MIT 13.003).
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14 — SPECIALTY SERVICES
This indicator focuses on specialist care from the time a request for
Case Review Rating:
services or physician’s order for specialist care is completed to the
Adequate
time of receipt of related recommendations from specialists. This Compliance Score:
indicator also evaluates the providers’ timely review of specialist Inadequate
records and documentation reflecting the patients’ care plans, (72.3%)
including course of care when specialist recommendations were not Overall Rating:
ordered, and whether the results of specialists’ reports are Adequate
communicated to the patients. For specialty services denied by the
institution, the OIG determines whether the denials are timely and
appropriate, and whether the patient is updated on the plan of care.
In this indicator, the OIG case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance testing an inadequate score. The
OIG’s internal review process considered the factors leading to both scores and ultimately
determined the overall rating was adequate, mainly because the findings from case review showed
very few deficiencies, which did not compromise the quality of care.
Case Review Results
The OIG clinicians reviewed 150 events related to Specialty Services, the majority of which were
specialty consultations (84 offsite and 8 onsite) and procedures (12). There were 17 deficiencies, 9
of which were related to health information management. There were four significant deficiencies.
Access to Specialty Services
Specialty services were provided in a timely manner in most cases. There was no pattern of delay in
providing specialty services. There were, however, three significant delays in follow-up with
specialists:
In case 2, the patient returned from a hospitalization for seizures. The provider ordered a
neurology follow-up, but the appointment was not scheduled. The patient continued to have
seizures and required a subsequent hospitalization.
In case 17, the patient underwent spinal surgery to treat an abscess that had developed near
the spinal cord. The surgeon requested a follow-up within two weeks, but the appointment
did not occur until five weeks after the surgery. Fortunately, there were no immediate
surgical complications.
In case 26, the patient underwent surgery to remove his gallbladder. The provider ordered a
two-week follow-up with the surgeon, but the appointment was not scheduled until four
weeks after the surgery. Fortunately, there were no immediate surgical complications.
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Nursing Performance
There were 24 specialty nursing events reviewed. TTA nurses reviewed the status and specialists’
recommendations for patients returning to SATF from offsite consultations. The nurses reviewed
the findings and recommendations from the specialty consultant, appropriately conveyed them to
the on-call provider, and obtained orders needed for the recommended care. TTA nurses contacted
specialists for clarification when the specialist reports were missing or illegible. Specialty
telemedicine nurses coordinated telemedicine schedules, assisted telemedicine providers with
patient evaluations, and retrieved necessary consultation reports to ensure availability during
appointments.
Provider Performance
In general, SATF medical providers ordered specialty services to occur within appropriate time
frames. Requests for specialty services were reviewed in a timely manner by the CME. After
patients’ specialty appointments, the consultation reports were often not signed off by providers
prior to being scanned into the electronic medical records. Despite this, most specialist
recommendations were timely implemented by the providers. There was no pattern of deficiencies.
Health Information Management
Consultation reports were generally retrieved promptly and scanned into the electronic medical
records. However, there were nine health information management deficiencies, six of which
involved reports being scanned prior to provider review and signature. One of these was significant:
In case 9, the cardiology consultation report was scanned into the electronic medical record
without being reviewed or signed by the medical provider. As the provider was unaware of
the recommendations, the provider did not promptly follow the recommendations. This
contributed to a delay in performing the needed heart test (cardiac catheterization).
Clinician Onsite Inspection
The OIG confirmed that specialty reports were scanned into the electronic medical records without
a provider review or signature. While this did not often hinder patient care, some problems, such as
that in case 9 (above), occasionally happened. This was also found in the OIG’s Cycle 4 inspection.
SATF leadership explained that there were personnel changes in health information management
and the utilization management staff who dealt with specialty services. These changes may have
contributed to some deficiencies. However, specialty services were, in general, functioning
adequately for the needs of the patients at SATF.
Case Review Conclusion
Patients were provided adequate, appropriate, and timely specialty services. Both nursing and
provider performances were satisfactory. Specialty report handling was problematic, as many of
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those reports were scanned into the medical record without a provider review. The OIG clinicians
rated this indicator adequate.
Compliance Testing Results
The institution received an inadequate compliance score of 72.3 percent in the Specialty Services
indicator. The following tests showed areas for needed improvement:
SATF timely received, and providers timely reviewed, 8 of the 14 applicable routine
specialists’ reports that inspectors sampled (57 percent). Providers reviewed the reports for
three patients from four to six days late; one patient’s report was reviewed 25 days late; for
two final patients, there was no evidence found that their reports were either received by the
institution or reviewed by a provider (MIT 14.004).
When patients are approved or scheduled for specialty service appointments at one
institution and then transfer to another, policy requires that the receiving institution
reschedule and provide the patient’s appointment within the required time frame. Only 12 of
the 20 applicable patients sampled who transferred to SATF with an approved specialty
service appointment (60 percent) received it within the required time frame. The remaining
eight patients did not timely receive their previously approved appointments. One patient
received his appointment one day late; three patients received their appointments 22, 37, and
59 days late; one patient received his appointment 152 days late; and three patients did not
receive their appointments (MIT 14.005).
The institution timely denied providers’ specialty service requests for 10 of 16 patients
sampled (63 percent). Five specialty services requests were denied between one and eight
days late; one request was denied 53 days late (MIT 14.006).
The institution timely received, and providers timely reviewed, high-priority specialists’
reports for 10 of 15 patients sampled (67 percent). For one patient, the report was received
by the institution one day late; for two patients, the reports were reviewed by a provider 12
and 14 days late; for another patient, there was no evidence found that a provider had
reviewed the report; and for one final patient, there was no evidence found that a report was
either received or reviewed (MIT 14.002).
Among 15 applicable patients sampled for whom SATF’s health care management denied a
specialty service, only ten (67 percent) received a timely notification of the denied service,
including the provider meeting with the patient within 30 days to discuss alternate treatment
strategies. For one patient, the provider’s follow-up visit occurred 11 days late; for the other
four patients, there was no evidence found of a provider follow-up to discuss the denial
(MIT 14.007).
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Two tests in this indicator received scores in the proficient range:
For all 15 patients sampled, routine specialty service appointments occurred within 90
calendar days of the provider’s order (MIT 14.003).
For 14 of 15 patients sampled (93 percent), high-priority specialty service appointments
occurred within 14 calendar days of the provider’s order; however, one patient received his
specialty service one day late (MIT 14.001).
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15 — ADMINISTRATIVE OPERATIONS(SECONDARY)
This indicator focuses on the institution’s administrative health care
Case Review Rating:
oversight functions. The OIG evaluates whether the institution
Not Applicable
promptly processes patient medical appeals and addresses all
Compliance Score:
appealed issues. Inspectors also verify that the institution follows Adequate
reporting requirements for adverse/sentinel events and inmate (78.4%)
deaths. The OIG verifies that the Emergency Medical Response
Overall Rating:
Review Committee (EMRRC) performs required reviews and that
Adequate
staff perform required emergency response drills. Inspectors also
assess whether the Quality Management Committee (QMC) meets
regularly and adequately addresses program performance. For those institutions with licensed
facilities, inspectors also verify that required committee meetings are held. In addition, OIG
examines whether the institution adequately manages its health care staffing resources by evaluating
whether job performance reviews are completed as required; specified staff possess current, valid
credentials and professional licenses or certifications; nursing staff receive new employee
orientation training and annual competency testing; and clinical and custody staff have current
medical emergency response certifications. The Administrative Operations indicator is a secondary
indicator, and, therefore, was not relied on for the overall score for the institution.
Compliance Testing Results
The institution performed in the adequate range in the Administrative Operations indicator,
receiving a compliance score of 78.4 percent. Several tests earned scores of 100 percent, as follows:
The institution promptly processed all inmate medical appeals in each of the most recent 12
months (MIT 15.001).
The OIG inspected incident package documentation for 12 emergency medical responses
reviewed by SATF’s Emergency Medical Response Review Committee (EMRRC) during
the prior six month period; all 12 sampled packages complied with policy (MIT 15.005).
Inspectors reviewed the last 12 months of SATF’s local governing body (LGB) meeting
minutes and determined that the LGB met at least quarterly and exercised responsibility for
the quality management of patient heath care each quarter, as documented in the meeting
minutes. As a result, SATF scored 100 percent on this test (MIT 15.006).
Based on a sample of ten second-level medical appeals, the institution’s responses addressed
all of the patients’ appealed issues (MIT 15.102).
Medical staff promptly submitted the initial Inmate Death Report (CDCR Form 7229A) to
CCHCS’s Death Review Unit for all three applicable deaths that occurred at SATF in the
prior 12-month period (MIT 15.103).
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The OIG’s inspectors examined the nursing reviews completed by five different nursing
supervisors for their subordinate nurses; in all instances, the reviews were sufficiently
completed (MIT 15.104).
All ten nurses sampled were current with their clinical competency validations (MIT
15.105).
The OIG reviewed performance evaluation packets for SATF’s ten providers; SATF met all
performance review requirements for its providers (MIT 15.106).
All providers at the institution were current with their professional licenses. Similarly, all
nursing staff and the pharmacist in charge were current with their professional licenses and
certification requirements (MIT 15.107, 15.109).
All active duty providers and nurses were current with their emergency response
certifications (MIT 15.108).
All pharmacy staff and providers who prescribed controlled substances had current Drug
Enforcement Agency registrations (MIT 15.110).
All nursing staff hired within the last year timely received new employee orientation training
(MIT 15.111).
The following tests scored in the inadequate range:
The OIG reviewed the two reported adverse/sentinel events (ASE) that occurred at SATF
during the prior 12-month period, each of which required a root-cause analysis and four
monthly status reports per the plan of action. One ASE was reported to CCHCS’s ASE
Committee three days late; the ASE report was 19 days late; and no evidence was found that
SATF submitted any of the required monthly status reports. For the second ASE, the
institution did not submit the fourth monthly status report. As a result, SATF received a
score of zero on this test (MIT 15.002).
The QMC did not document discussions of the methodologies used to conduct periodic data
validation of the institution’s Dashboard data, or document discussions on the
methodologies used to train the staff who collected the Dashboard data. Therefore, SATF
received a score of zero on this test (MIT 15.004).
The institution did not meet the emergency response drill requirements for the most recent
quarter for each of its three watches, resulting in a score of zero. More specifically, the
institution’s first watch drill package did not contain a First Medical Responder–Data
Collection Tool (CDCR Form 7463). The second watch drill package did not contain a
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Triage and Treatment Services Flow Sheet (CDCR Form 7464); and the third watch drill
package had multiple incomplete required forms (MIT 15.101).
Inspectors reviewed six recent months’ QMC meeting minutes and confirmed that for only
two of the six tested months, the QMC evaluated program performance and took action
when it identified improvement opportunities (33 percent) (MIT 15.003).
Non-Scored Results
The OIG gathered non-scored data regarding the completion of death review reports by
CCHCS’s Death Review Committee (DRC). Seven deaths occurred during the OIG’s review
period: two unexpected (Level 1), and five expected (Level 2). The DRC was required to
complete its death review summary report within 60 days from the date of death for the
Level 1 deaths and within 30 days from the date of death for the Level 2 deaths; the reports
should then have been submitted to the institution’s chief executive officer (CEO) within
seven calendar days thereafter. However, for the two Level 1 deaths, the DRC completed its
reports 9 and 43 days late (69 and 103 days after death) and submitted them to SATF’s CEO
61 and 49 days late; for three of the five Level 2 deaths, the DRC completed its reports 18,
47, and 66 days late (48, 77, and 96 days after death) and submitted them to the CEO 34, 54,
and 79 days late; for the final two Level 2 deaths, the DRC completed its reports 25 and 29
days late (55 and 59 days after death), and the reports had not yet been submitted to the CEO
at the time of the OIG’s inspection (MIT 15.998).
The OIG discusses the institution’s health care staffing resources in the About the Institution
section of this report (MIT 15.999).
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R
ECOMMENDATIONS
The OIG recommends SATF provide training for health information management staff to
ensure reports are reviewed and signed by providers prior to being scanned into medical
records. When the EHRS is implemented, SATF should ensure that the health information
management staff sends reports to providers for their review and signature electronically.
The OIG recommends SATF leadership deliver training to providers regarding careful
review of medical records for complex patients, such as those cared for in the CTC. This is
especially important for providers who are unfamiliar with the patients because the
providers are on call or covering on weekends. In addition, the OIG recommends that SATF
train providers about the importance of careful record review for patients returning from
outside hospitals to ensure that all diagnoses and management plans are appropriately
addressed.
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Office of the Inspector General State of California
P -B M
OPULATION ASED ETRICS
The compliance testing and the case reviews give an accurate assessment of how the institution’s
health care systems are functioning with regard to the patients with the highest risk and utilization.
This information is vital to assess the capacity of the institution to provide sustainable, adequate
care. However, one significant limitation of the case review methodology is that it does not give a
clear assessment of how the institution performs for the entire population. For better insight into this
performance, the OIG has turned to population-based metrics. For comparative purposes, the OIG
has selected several Healthcare Effectiveness Data and Information Set (HEDIS) measures for
disease management to gauge the institution’s effectiveness in outpatient health care, especially
chronic disease management.
The Healthcare Effectiveness Data and Information Set is a set of standardized performance
measures developed by the National Committee for Quality Assurance with input from over 300
organizations representing every sector of the nation’s health care industry. It is used by over
90 percent of the nation’s health plans as well as many leading employers and regulators. It was
designed to ensure that the public (including employers, the Centers for Medicare and Medicaid
Services, and researchers) has the information it needs to accurately compare the performance of
health care plans. Healthcare Effectiveness Data and Information Set data is often used to produce
health plan report cards, analyze quality improvement activities, and create performance
benchmarks.
Methodology
For population-based metrics, the OIG used a subset of HEDIS measures applicable to the CDCR
inmate-patient population. Selection of the measures was based on the availability, reliability, and
feasibility of the data required for performing the measurement. The OIG collected data utilizing
various information sources, including the eUHR, the Master Registry (maintained by CCHCS), as
well as a random sample of patient records analyzed and abstracted by trained personnel. Data
obtained from the CCHCS Master Registry and Diabetic Registry was not independently validated
by the OIG and is presumed to be accurate. For some measures, the OIG used the entire population
rather than statistically random samples. While the OIG is not a certified HEDIS compliance
auditor, the OIG uses similar methods to ensure that measures are comparable to those published by
other organizations.
Comparison of Population-Based Metrics
For the California Substance Abuse Treatment Facility and State Prison at Corcoran, nine HEDIS
measures were selected and are listed in the following SATF Results Compared to State and
National HEDIS Scores table. Multiple health plans publish their HEDIS performance measures at
the State and national levels. The OIG has provided selected results for several health plans in both
categories for comparative purposes.
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 60
Office of the Inspector General State of California
Results of Population-Based Metric Comparison
Comprehensive Diabetes Care
For chronic care management, the OIG chose measures related to the management of diabetes.
Diabetes is the most complex common chronic disease requiring a high level of intervention on the
part of the health care system in order to produce optimal results. SATF performed well with its
management of diabetes.
When compared statewide, SATF outperformed Medi-Cal in four of the five measures, scoring
slightly lower in regard to diabetic eye exams. SATF outperformed Kaiser north and south in three
of the five measures, scoring slightly lower in diabetic blood pressure control and eye exams.
When compared nationally, SATF scored higher than Medicaid, commercial health plans, and
Medicare, in four of the five diabetic measures, and scored higher than the United States
Department of Veterans Affairs (VA) in three of four measures. SATF scored lower in diabetic eye
exams compared to all of the national entities. However, the 22 percent refusal rate for eye exams
negatively affected the institutions score.
Immunizations
Comparative data for immunizations was only fully available for the VA and partially available for
Kaiser, commercial plans, Medicaid, and Medicare. With respect to administering influenza
vaccinations to younger adults, SATF scored higher than all Medicaid and commercial health plans,
but lower than Kaiser (both North and South) and the VA. The high patient refusal rate of 49
percent for influenza vaccinations to younger adults negatively affected the institutions score.
When administering influenza vaccinations to older adults, SATF scored higher than Medicare and
matched the VA. With regard to administering pneumococcal vaccines to older adults, SATF scored
lower than both Medicare and the VA.
Cancer Screening
With respect to colorectal cancer screening, SATF scored higher than commercial health plans and
matched Medicare, but scored lower than Kaiser (both North and South) and the VA. However, the
institution’s score was negatively affected by a 31 percent refusal rate.
Summary
SATF’s population-based metrics performance reflected an adequate chronic care program, and is
comparable to the other health care plans reviewed. The institution may improve its scores for
diabetic eye exams, influenza vaccinations for young adults, and colorectal cancer screenings by
reducing patient refusals through educating patients on the benefits of these preventive services.
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 61
Office of the Inspector General State of California
SATF Results Compared to State and National HEDIS Scores
California National
Clinical Measures SATF HEDIS HEDIS HEDIS HEDIS
Medi- Kaiser Kaiser HEDIS Com- HEDIS VA
Cycle 5 Cal (No.CA) (So.CA) Medicaid mercial Medicare Average
Results1 20152 20163 20163 20164 20164 20164 20155
Comprehensive Diabetes Care
HbA1c Testing (Monitoring) 100% 86% 94% 94% 86% 90% 93% 98%
Poor HbA1c Control (>9.0%)6, 7 16% 39% 20% 23% 45% 34% 27% 19%
HbA1c Control (<8.0%)6 72% 49% 70% 63% 46% 55% 63% -
Blood Pressure Control (<140/90) 82% 63% 83% 83% 59% 60% 62% 74%
Eye Exams 46% 53% 68% 81% 53% 54% 69% 89%
Immunizations
Influenza Shots - Adults (18–64) 51% - 56% 57% 39% 48% - 55%
Influenza Shots - Adults (65+) 76% - - - - - 72% 76%
Immunizations: Pneumococcal 61% - - - - - 71% 93%
Cancer Screening
Colorectal Cancer Screening 67% - 79% 82% - 63% 67% 82%
1. Unless otherwise stated, data was collected in April 2017 by reviewing medical records from a sample of SATF's population of
applicable inmate-patients. These random statistical sample sizes were based on a 95 percent confidence level with a 15 percent
maximum margin of error.
2. HEDIS Medi-Cal data was obtained from the California Department of Health Care Services 2015 HEDIS Aggregate Report
for Medi-Cal Managed Care.
3. Data was obtained from Kaiser Permanente November 2016 reports for the Northern and Southern California regions.
4. National HEDIS data for Medicaid, commercial plans, and Medicare was obtained from the 2016 State of Health Care Quality
Report, available on the NCQA website: www.ncqa.org. The results for commercial plans were based on data received from
various health maintenance organizations.
5. The Department of Veterans Affairs (VA) data was obtained from the VA's website, www.va.gov.
For the Immunizations: Pneumococcal measure only, the data was obtained from the VHA Facility Quality and Safety Report -
Fiscal Year 2012 Data.
6. For this indicator, the entire applicable SATF population was tested.
7. For this measure only, a lower score is better. For Kaiser, the OIG derived the Poor HbA1c Control indicator using the reported
data for the <9.0% HbA1c control indicator.
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 62
Office of the Inspector General State of California
A A — C T R
PPENDIX OMPLIANCE EST ESULTS
SATF
Range of Summary Scores: 54.91% - 85.00%
Indicator Compliance Score (Yes %)
1–Access to Care 71.72%
2–Diagnostic Services 54.91%
3–Emergency Services Not Applicable
4–Health Information Management (Medical Records) 60.72%
5–Health Care Environment 69.42%
6–Inter- and Intra-System Transfers 80.67%
7–Pharmacy and Medication Management 72.66%
8–Prenatal and Post-Delivery Services Not Applicable
9–Preventive Services 77.89%
10–Quality of Nursing Performance Not Applicable
11–Quality of Provider Performance Not Applicable
12–Reception Center Arrivals Not Applicable
13–Specialized Medical Housing (OHU, CTC, SNF, Hospice) 85.00%
14–Specialty Services 72.33%
15–Administrative Operations 78.43%
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 63
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
1–Access to Care
Number Yes No No Yes % N/A
Chronic care follow-up appointments: Was the patient’s most
recent chronic care visit within the health care guideline’s
1.001 8 16 24 33.33% 1
maximum allowable interval or within the ordered time frame,
whichever is shorter?
For endorsed patients received from another CDCR institution: If
1.002 the nurse referred the patient to a provider during the initial health 16 9 25 64.00% 0
screening, was the patient seen within the required time frame?
Clinical appointments: Did a registered nurse review the patient’s
1.003 52 3 55 94.55% 0
request for service the same day it was received?
Clinical appointments: Did the registered nurse complete a
1.004 face-to-face visit within one business day after the CDCR Form 52 2 54 96.30% 1
7362 was reviewed?
Clinical appointments: If the registered nurse determined a
referral to a primary care provider was necessary, was the patient
1.005 9 12 21 42.86% 34
seen within the maximum allowable time or the ordered time
frame, whichever is the shorter?
Sick call follow-up appointments: If the primary care provider
1.006 ordered a follow-up sick call appointment, did it take place within 9 1 10 90.00% 45
the time frame specified?
Upon the patient’s discharge from the community hospital: Did
1.007 the patient receive a follow-up appointment within the required 21 4 25 84.00% 0
time frame?
Specialty service follow-up appointments: Do specialty service
1.008 primary care physician follow-up visits occur within required time 16 12 28 57.14% 2
frames?
Clinical appointments: Do patients have a standardized process to
1.101 5 1 6 83.33% 1
obtain and submit health care services request forms?
Overall percentage: 71.72
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 64
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
2–Diagnostic Services
Number Yes No No Yes % N/A
Radiology: Was the radiology service provided within the time
2.001 8 2 10 80.00% 0
frame specified in the provider’s order?
Radiology: Did the primary care provider review and initial the
2.002 0 10 0 0.00% 0
diagnostic report within specified time frames?
Radiology: Did the primary care provider communicate the results
2.003 3 7 10 30.00% 0
of the diagnostic study to the patient within specified time frames?
Laboratory: Was the laboratory service provided within the time
2.004 7 1 8 87.50% 2
frame specified in the provider’s order?
Laboratory: Did the primary care provider review and initial the
2.005 9 0 9 100.00% 1
diagnostic report within specified time frames?
Laboratory: Did the primary care provider communicate the
2.006 results of the diagnostic study to the patient within specified time 5 4 9 55.56% 1
frames?
Pathology: Did the institution receive the final diagnostic report
2.007 7 3 10 70.00% 0
within the required time frames?
Pathology: Did the primary care provider review and initial the
2.008 6 4 10 60.00% 0
diagnostic report within specified time frames?
Pathology: Did the primary care provider communicate the results
2.009 1 8 9 11.11% 1
of the diagnostic study to the patient within specified time frames?
Overall percentage: 54.91%
3–Emergency Services
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 65
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
4–Health Information Management
Number Yes No No Yes % N/A
Are non-dictated healthcare documents (provider progress notes)
4.001 19 1 20 95.00% 0
scanned within 3 calendar days of the patient encounter date?
Are dictated/transcribed documents scanned into the patient’s
4.002 electronic health record within five calendar days of the encounter Not Applicable
date?
Are High-Priority specialty notes (either a Form 7243 or other
4.003 scanned consulting report) scanned within the required time 17 3 20 85.00% 0
frame?
Are community hospital discharge documents scanned into the
4.004 patient’s electronic health record within three calendar days of 15 3 18 83.33% 0
hospital discharge?
Are medication administration records (MARs) scanned into the
4.005 13 7 20 65.00% 0
patient’s electronic health record within the required time frames?
During the inspection, were medical records properly scanned,
4.006 0 24 24 0.00% 0
labeled, and included in the correct patients’ files?
For patients discharged from a community hospital: Did the
preliminary hospital discharge report include key elements and
4.007 9 16 25 36.00% 0
did a primary care provider review the report within three
calendar days of discharge?
Overall percentage: 60.72%
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 66
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
5–Health Care Environment
Number Yes No No Yes % N/A
Are clinical health care areas appropriately disinfected, cleaned
5.101 12 0 12 100.00% 0
and sanitary?
Do clinical health care areas ensure that reusable invasive and
5.102 non-invasive medical equipment is properly sterilized or 9 3 12 75.00% 0
disinfected as warranted?
Do clinical health care areas contain operable sinks and sufficient
5.103 10 2 12 83.33% 0
quantities of hygiene supplies?
Does clinical health care staff adhere to universal hand hygiene
5.104 5 7 12 41.67% 0
precautions?
Do clinical health care areas control exposure to blood-borne
5.105 7 5 12 58.33% 0
pathogens and contaminated waste?
Warehouse, Conex and other non-clinic storage areas: Does the
5.106 medical supply management process adequately support the needs 1 0 1 100.00% 0
of the medical health care program?
Does each clinic follow adequate protocols for managing and
5.107 9 3 12 75.00% 0
storing bulk medical supplies?
Do clinic common areas and exam rooms have essential core
5.108 5 7 12 41.67% 0
medical equipment and supplies?
Do clinic common areas have an adequate environment conducive
5.109 9 3 12 75.00% 0
to providing medical services?
Do clinic exam rooms have an adequate environment conducive
5.110 6 6 12 50.00% 0
to providing medical services?
Emergency response bags: Are TTA and clinic emergency
5.111 medical response bags inspected daily and inventoried monthly, 7 4 11 63.64% 1
and do they contain essential items?
Overall percentage: 69.42%
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 67
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
6–Inter- and Intra-System Transfers
Number Yes No No Yes % N/A
For endorsed patients received from another CDCR institution or
COCF: Did nursing staff complete the initial health screening and
6.001 20 4 24 83.33% 1
answer all screening questions on the same day the patient arrived
at the institution?
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
disposition section of the health screening form; refer the patient
6.002 24 0 24 100.00% 1
to the TTA, if TB signs and symptoms were present; and sign and
date the form on the same day staff completed the health
screening?
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon
6.003 9 9 18 50.00% 7
arrival, were medications administered or delivered without
interruption?
For patients transferred out of the facility: Were scheduled
6.004 specialty service appointments identified on the patient’s health 14 6 20 70.00% 0
care transfer information form?
For patients transferred out of the facility: Do medication transfer
6.101 packages include required medications along with the 2 0 2 100.00% 0
corresponding transfer packet required documents?
Overall percentage: 80.67%
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 68
Office of the Inspector General State of California
Scored Answers
7–Pharmacy and Medication Yes
Reference +
Management
Number Yes No No Yes % N/A
Did the patient receive all chronic care medications within the
7.001 required time frames or did the institution follow departmental 17 4 21 80.95% 4
policy for refusals or no-shows?
Did health care staff administer, make available, or deliver new
7.002 order prescription medications to the patient within the required 25 0 25 100.00% 0
time frames?
Upon the patient’s discharge from a community hospital: Were all
7.003 ordered medications administered, made available, or delivered to 11 12 23 47.83% 2
the patient within required time frames?
For patients received from a county jail: Were all medications
ordered by the institution’s reception center provider
7.004 Not Applicable
administered, made available, or delivered to the patient within
the required time frames?
Upon the patient’s transfer from one housing unit to another:
7.005 21 4 25 84.00% 0
Were medications continued without interruption?
For patients en route who lay over at the institution: If the
7.006 temporarily housed patient had an existing medication order, were 3 2 5 60.00% 0
medications administered or delivered without interruption?
All clinical and medication line storage areas for narcotic
7.101 medications: Does the Institution employ strong medication 2 9 11 18.18% 0
security over narcotic medications assigned to its clinical areas?
All clinical and medication line storage areas for non-narcotic
medications: Does the Institution properly store non-narcotic
7.102 2 8 10 20.00% 1
medications that do not require refrigeration in assigned clinical
areas?
All clinical and medication line storage areas for non-narcotic
7.103 medications: Does the institution properly store non-narcotic 7 4 11 63.64% 0
medications that require refrigeration in assigned clinical areas?
Medication preparation and administration areas: Do nursing staff
employ and follow hand hygiene contamination control protocols
7.104 5 3 8 62.50% 3
during medication preparation and medication administration
processes?
Medication preparation and administration areas: Does the
7.105 institution employ appropriate administrative controls and 8 0 8 100.00% 3
protocols when preparing medications for patients?
Medication preparation and administration areas: Does the
7.106 Institution employ appropriate administrative controls and 3 5 8 37.50% 3
protocols when distributing medications to patients?
Pharmacy: Does the institution employ and follow general
7.107 security, organization, and cleanliness management protocols in 1 0 1 100.00% 0
its main and satellite pharmacies?
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 69
Office of the Inspector General State of California
Scored Answers
7–Pharmacy and Medication Yes
Reference +
Management
Number Yes No No Yes % N/A
Pharmacy: Does the institution’s pharmacy properly store
7.108 1 0 1 100.00% 0
non-refrigerated medications?
Pharmacy: Does the institution’s pharmacy properly store
7.109 1 0 1 100.00% 0
refrigerated or frozen medications?
Pharmacy: Does the institution’s pharmacy properly account for
7.110 1 0 1 100.00% 0
narcotic medications?
Does the institution follow key medication error reporting
7.111 22 3 25 88.00% 0
protocols?
Overall percentage: 72.66%
8–Prenatal and Post-Delivery Services
The institution has no female patients, so this indicator is not applicable.
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
9–Preventive Services
Number Yes No No Yes % N/A
Patients prescribed TB medication: Did the institution administer
9.001 8 4 12 66.67% 0
the medication to the patient as prescribed?
Patients prescribed TB medication: Did the institution monitor the
9.002 patient monthly for the most recent three months he or she was on 4 8 12 33.33% 0
the medication?
Annual TB Screening: Was the patient screened for TB within the
9.003 29 1 30 96.67% 0
last year?
Were all patients offered an influenza vaccination for the most
9.004 25 0 25 100.00% 0
recent influenza season?
All patients from the age of 50 - 75: Was the patient offered
9.005 24 1 25 96.00% 0
colorectal cancer screening?
Female patients from the age of 50 through the age of 74: Was the
9.006 Not Applicable
patient offered a mammogram in compliance with policy?
Female patients from the age of 21 through the age of 65: Was
9.007 Not Applicable
patient offered a pap smear in compliance with policy?
Are required immunizations being offered for chronic care
9.008 16 2 18 88.89% 7
patients?
Are patients at the highest risk of coccidioidomycosis (valley
9.009 7 4 11 63.64% 0
fever) infection transferred out of the facility in a timely manner?
Overall percentage: 77.89%
10–Quality of Nursing Performance
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
11–Quality of Provider Performance
This indicator is evaluated only by case review clinicians. There is no compliance testing component.
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 71
Office of the Inspector General State of California
12–Reception Center Arrivals
The institution has no reception center, so this indicator is not applicable.
Scored Answers
Yes
Reference +
13–Specialized Medical Housing
Number Yes No No Yes % N/A
For OHU, CTC, and SNF: Did the registered nurse complete an
13.001 initial assessment of the patient on the day of admission, or within 10 0 10 100.00% 0
eight hours of admission to CMF’s Hospice?
For CTC and SNF only: Was a written history and physical
13.002 7 3 10 70.00% 0
examination completed within the required time frame?
For OHU, CTC, SNF, and Hospice: Did the primary care provider
complete the Subjective, Objective, Assessment, Plan, and
13.003 7 3 10 70.00% 0
Education (SOAPE) notes on the patient at the minimum intervals
required for the type of facility where the patient was treated?
For OHU and CTC Only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
13.101 1 0 1 100.00% 0
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells?
Overall percentage: 85.00%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
14–Specialty Services
Number Yes No No Yes % N/A
Did the patient receive the high priority specialty service within
14.001 14 calendar days of the primary care provider order or the 14 1 15 93.33% 0
Physician Request for Service?
Did the primary care provider review the high priority specialty
14.002 10 5 15 66.67% 0
service consultant report within the required time frame?
Did the patient receive the routine specialty service within 90
14.003 calendar days of the primary care provider order or Physician 15 0 15 100.00% 0
Request for Service?
Did the primary care provider review the routine specialty service
14.004 8 6 14 57.14% 1
consultant report within the required time frame?
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at
14.005 12 8 20 60.00% 0
the sending institution, was the appointment scheduled at the
receiving institution within the required time frames?
Did the institution deny the primary care provider request for
14.006 10 6 16 62.50% 0
specialty services within required time frames?
Following the denial of a request for specialty services, was the
14.007 10 5 15 66.67% 1
patient informed of the denial within the required time frame?
Overall percentage: 72.33%
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 73
Office of the Inspector General State of California
Scored Answers
Yes
Reference
15–Administrative Operations +
Number Yes No No Yes % N/A
Did the institution promptly process inmate medical appeals
15.001 12 0 12 100.00% 0
during the most recent 12 months?
Does the institution follow adverse / sentinel event reporting
15.002 0 2 2 0.00% 0
requirements?
Did the institution Quality Management Committee (QMC) meet
at least monthly to evaluate program performance, and did the
15.003 2 4 6 33.33% 0
QMC take action when improvement opportunities were
identified?
Did the institution’s Quality Management Committee (QMC) or
15.004 other forum take steps to ensure the accuracy of its Dashboard 0 1 1 0.00% 0
data reporting?
Does the Emergency Medical Response Review Committee
15.005 perform timely incident package reviews that include the use of 12 0 12 100.00% 0
required review documents?
For institutions with licensed care facilities: Does the Local
Governing Body (LGB), or its equivalent, meet quarterly and
15.006 4 0 4 100.00% 0
exercise its overall responsibilities for the quality management of
patient health care?
Did the institution complete a medical emergency response drill
15.101 for each watch and include participation of health care and 0 3 3 0.00% 0
custody staff during the most recent full quarter?
Did the institution’s second level medical appeal response address
15.102 10 0 10 100.00% 0
all of the patient’s appealed issues?
Did the institution’s medical staff review and submit the initial
15.103 3 0 3 100.00% 0
inmate death report to the Death Review Unit in a timely manner?
Does the institution’s Supervising Registered Nurse conduct
15.104 5 0 5 100.00% 0
periodic reviews of nursing staff?
Are nursing staff who administer medications current on their
15.105 10 0 10 100.00% 0
clinical competency validation?
15.106 Are structured clinical performance appraisals completed timely? 10 0 10 100.00% 0
15.107 Do all providers maintain a current medical license? 13 0 13 100.00% 0
Are staff current with required medical emergency response
15.108 2 0 2 100.00% 1
certifications?
Are nursing staff and the Pharmacist-in-Charge current with their
professional licenses and certifications, and is the pharmacy
licensed as a correctional pharmacy by the California State Board
15.109 6 0 6 100.00% 1
of Pharmacy?
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 74
Office of the Inspector General State of California
Scored Answers
Yes
Reference
15–Administrative Operations +
Number Yes No No Yes % N/A
Do the institution’s pharmacy and authorized providers who
15.110 prescribe controlled substances maintain current Drug 1 0 1 100.00% 0
Enforcement Agency (DEA) registrations?
15.111 Are nursing staff current with required new employee orientation? 1 0 1 100.00% 0
Overall percentage: 78.43%
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 75
Office of the Inspector General State of California
A B — C D
PPENDIX LINICAL ATA
Table B-1: SATF Sample Sets
Sample Set Total
Anticoagulation 3
Death Review/Sentinel Events 3
Diabetes 3
Emergency Services – CPR 1
Emergency Services – Non-CPR 3
High Risk 5
Hospitalization 4
Intra-System Transfers In 3
Intra-System Transfers Out 3
RN Sick Call 32
Specialty Services 4
64
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Office of the Inspector General State of California
Table B-2: SATF Chronic Care Diagnoses
Diagnosis Total
Anemia 5
Anticoagulation 4
Arthritis/Degenerative Joint Disease 6
Asthma 12
COPD 9
Cancer 6
Cardiovascular Disease 11
Chronic Kidney Disease 5
Chronic Pain 19
Cirrhosis/End-Stage Liver Disease 2
Deep Venous Thrombosis/Pulmonary Embolism 2
Diabetes 20
Gastroesophageal Reflux Disease 8
Hepatitis C 19
Hyperlipidemia 20
Hypertension 37
Mental Health 3
Seizure Disorder 6
Sleep Apnea 3
197
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 77
Office of the Inspector General State of California
Table B-3: SATF Event – Program
Program Total
Diagnostic Services 192
Emergency Care 49
Hospitalization 39
Intra-system Transfers-In 19
Intra-system Transfers-Out 8
Not Specified 5
Outpatient Care 487
Specialized Medical Housing 579
Specialty Services 153
1,531
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Office of the Inspector General State of California
Table B-4: SATF Review Sample Summary
Total
MD Reviews Detailed 25
MD Reviews Focused 0
RN Reviews Detailed 15
RN Reviews Focused 39
Total Reviews 79
Total Unique Cases 64
Overlapping Reviews (MD & RN) 15
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 79
Office of the Inspector General State of California
A C — C S M
PPENDIX OMPLIANCE AMPLING ETHODOLOGY
California Substance Abuse and Treatment Facility and
State Prison at Corcoran (SATF)
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Access to Care
MIT 1.001 Chronic Care Patients Master Registry Chronic care conditions (at least one condition per
patient—any risk level)
(25) Randomize
MIT 1.002 Nursing Referrals OIG Q: 6.001 See Intra-system Transfers
(25)
MITs 1.003–006 Nursing Sick Call MedSATS Clinic (each clinic tested)
(5 per clinic) Appointment date (2–9 months)
(55) Randomize
MIT 1.007 Returns from OIG Q: 4.007 See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(25)
MIT 1.008 Specialty Services OIG Q: 14.001 & See Specialty Services
Follow-up 14.003
(30)
MIT 1.101 Availability of Health OIG onsite Randomly select one housing unit from each yard
Care Services review
Request Forms
(6)
Diagnostic Services
MITs 2.001–003 Radiology Radiology Logs Appointment date (90 days–9 months)
Randomize
(10) Abnormal
MITs 2.004–006 Laboratory Quest Appt. date (90 days–9 months)
Order name (CBC or CMPs only)
Randomize
(10) Abnormal
MITs 2.007–009 Pathology InterQual Appt. date (90 days–9 months)
Service (pathology related)
(10) Randomize
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 80
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Timely Scanning OIG Qs: 1.001, Non-dictated documents
(20) 1.002, & 1.004 1st 10 IPs MIT 1.001, 1st 5 IPs MITs 1.002, 1.004
MIT 4.002 OIG Q: 1.001 Dictated documents
(0) First 20 IPs selected
MIT 4.003 OIG Qs: 14.002 Specialty documents
(20) & 14.004 First 10 IPs for each question
MIT 4.004 OIG Q: 4.007 Community hospital discharge documents
(18) First 20 IPs selected
MIT 4.005 OIG Q: 7.001 MARs
(20) First 20 IPs selected
MIT 4.006 Documents for Any misfiled or mislabeled document identified
(24) any tested inmate during OIG compliance review (24 or more = No)
MIT 4.007 Returns From Inpatient claims Date (2–8 months)
Community Hospital data Most recent 6 months provided (within date range)
Rx count
Discharge date
Randomize (each month individually)
First 5 patients from each of the 6 months (if not 5
in a month, supplement from another, as needed)
(25)
Health Care Environment
MIT 5.101–105 Clinical Areas OIG inspector Identify and inspect all onsite clinical areas.
MIT 5.107–111 (12) onsite review
Inter- and Intra-System Transfers
MIT 6.001–003 Intra-System SOMS Arrival date (3–9 months)
Transfers Arrived from (another CDCR facility)
Rx count
Randomize
(25)
MIT 6.004 Specialty Services MedSATS Date of transfer (3–9 months)
Send-Outs Randomize
(20)
MIT 6.101 Transfers Out OIG inspector R&R IP transfers with medication
(2) onsite review
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Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care OIG Q: 1.001 See Access to Care
Medication At least one condition per patient—any risk level
Randomize
(25)
MIT 7.002 New Medication Master Registry Rx count
Orders Randomize
(25) Ensure no duplication of IPs tested in MIT 7.001
MIT 7.003 Returns from OIG Q: 4.007 See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(25)
MIT 7.004 RC Arrivals – OIG Q: 12.001 See Reception Center Arrivals
Medication Orders
(N/A at this
institution)
MIT 7.005 Intra-Facility Moves MAPIP transfer Date of transfer (2–8 months)
data To location/from location (yard to yard and
to/from ASU)
Remove any to/from MHCB
NA/DOT meds (and risk level)
(25)
Randomize
MIT 7.006 En Route SOMS Date of transfer (2–8 months)
Sending institution (another CDCR facility)
Randomize
(5) NA/DOT meds
MITs 7.101–103 Medication Storage OIG inspector Identify and inspect clinical & med line areas that
Areas onsite review store medications
(varies by test)
MITs 7.104–106 Medication OIG inspector Identify and inspect onsite clinical areas that
Preparation and onsite review prepare and administer medications
Administration Areas
(varies by test)
MITs 7.107–110 Pharmacy OIG inspector Identify & inspect all onsite pharmacies
(1) onsite review
MIT 7.111 Medication Error Monthly All monthly statistic reports with Level 4 or higher
Reporting medication error Select a total of 5 months
(25) reports
MIT 7.999 Isolation Unit KOP Onsite active KOP rescue inhalers & nitroglycerin medications
Medications medication for IPs housed in isolation units
(7) listing
Prenatal and Post-Delivery Services
MIT 8.001–007 Recent Deliveries OB Roster Delivery date (2–12 months)
(N/A at this Most recent deliveries (within date range)
institution)
Pregnant Arrivals OB Roster Arrival date (2–12 months)
(N/A at this Earliest arrivals (within date range)
institution)
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 82
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Preventive Services
MITs 9.001–002 TB Medications Maxor Dispense date (past 9 months)
Time period on TB meds (3 months or 12 weeks)
(12) Randomize
MIT 9.003 TB Evaluation, SOMS Arrival date (at least 1 year prior to inspection)
Annual Screening Birth Month
(30) Randomize
MIT 9.004 Influenza SOMS Arrival date (at least 1 year prior to inspection)
Vaccinations Randomize
(25) Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer SOMS Arrival date (at least 1 year prior to inspection)
Screening Date of birth (51 or older)
(25) Randomize
MIT 9.006 Mammogram SOMS Arrival date (at least 2 yrs prior to inspection)
(N/A at this Date of birth (age 52–74)
institution) Randomize
MIT 9.007 Pap Smear SOMS Arrival date (at least three yrs prior to inspection)
(N/A at this Date of birth (age 24–53)
institution) Randomize
MIT 9.008 Chronic Care OIG Q: 1.001 Chronic care conditions (at least 1 condition per
Vaccinations IP—any risk level)
Randomize
(25) Condition must require vaccination(s)
MIT 9.009 Valley Fever Cocci transfer Reports from past 2–8 months
status report Institution
Ineligibility date (60 days prior to inspection date)
(11)
All
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 83
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Reception Center Arrivals
MITs 12.001–008 RC SOMS Arrival date (2–8 months)
(N/A at this Arrived from (county jail, return from parole, etc.)
institution) Randomize
Specialized Medical Housing
MITs 13.001–004 CTC CADDIS Admit date (1–6 months)
Type of stay (no MH beds)
Length of stay (minimum of 5 days)
(10)
Randomize
MIT 13.101 Call Buttons OIG inspector Review by location
CTC onsite review
(all)
Specialty Services
MITs 14.001–002 High-Priority MedSATS Approval date (3–9 months)
(15) Randomize
MITs 14.003–004 Routine MedSATS Approval date (3–9 months)
Remove optometry, physical therapy or podiatry
(15) Randomize
MIT 14.005 Specialty Services MedSATS Arrived from (other CDCR institution)
Arrivals Date of transfer (3–9 months)
(20) Randomize
MIT 14.006–007 Denials InterQual Review date (3–9 months)
(16) Randomize
IUMC/MAR Meeting date (9 months)
Meeting Minutes Denial upheld
(0) Randomize
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 84
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Administrative Operations
MIT 15.001 Medical Appeals Monthly medical Medical appeals (12 months)
(all) appeals reports
MIT 15.002 Adverse/Sentinel Adverse/sentinel Adverse/sentinel events (2–8 months)
Events events report
(2)
MITs 15.003–004 QMC Meetings Quality Meeting minutes (12 months)
Management
Committee
(6) meeting minutes
MIT 15.005 EMRRC EMRRC meeting Monthly meeting minutes (6 months)
(12) minutes
MIT 15.006 LGB LGB meeting Quarterly meeting minutes (12 months)
(4) minutes
MIT 15.101 Medical Emergency Onsite summary Most recent full quarter
Response Drills reports & Each watch
documentation
(3) for ER drills
MIT 15.102 2nd Level Medical Onsite list of Medical appeals denied (6 months)
Appeals appeals/closed
(10) appeals files
MIT 15.103 Death Reports Institution-list of Most recent 10 deaths
deaths in prior 12 Initial death reports
(3) months
MIT 15.104 RN Review Onsite supervisor RNs who worked in clinic or emergency setting
Evaluations periodic RN six or more days in sampled month
reviews Randomize
(5)
MIT 15.105 Nursing Staff Onsite nursing On duty one or more years
Validations education files Nurse administers medications
(10) Randomize
MIT 15.106 Provider Annual Onsite All required performance evaluation documents
Evaluation Packets provider
(10) evaluation files
MIT 15.107 Provider licenses Current provider Review all
listing (at start of
(13) inspection)
MIT 15.108 Medical Emergency Onsite All staff
Response certification o Providers (ACLS)
Certifications tracking logs o Nursing (BLS/CPR)
(all) Custody (CPR/BLS)
MIT 15.109 Nursing staff and Onsite tracking All required licenses and certifications
Pharmacist in system, logs, or
Charge Professional employee files
Licenses and
Certifications
(all)
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 85
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Administrative Operations
MIT 15.110 Pharmacy and Onsite listing of All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
(all) document
MIT 15.111 Nursing Staff New Nursing staff New employees (hired within last 12 months)
Employee training logs
Orientations
(all)
MIT 15.998 Death Review OIG summary Between 35 business days & 12 months prior
Committee log - deaths CCHCS death reviews
(7)
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 86
Office of the Inspector General State of California
C C
ALIFORNIA ORRECTIONAL
H C S ’
EALTH ARE ERVICES
R
ESPONSE
California Substance Abuse Treatment Facility, Cycle 5 Medical Inspection Page 87
Office of the Inspector General State of California