OIG
Sierra Conservation Center Cycle 7 Medical Inspection Report
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Cycle 7, Sierra Conservation Center | iii
Contents
Illustrations iv
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 6
Institution-Specific Metrics 6
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 14
Access to Care 14
Diagnostic Services 22
Emergency Services 27
Health Information Management 33
Health Care Environment 40
Transfers 46
Medication Management 54
Preventive Services 62
Nursing Performance 65
Provider Performance 72
Specialized Medical Housing 80
Specialty Services 83
Administrative Operations 90
Appendix A: Methodology 93
Case Reviews 94
Compliance Testing 97
Indicator Ratings and the Overall Medical Quality Rating 98
Appendix B: Case Review Data 99
Appendix C: Compliance Sampling Methodology 103
California Correctional Health Care Services’ Response 111
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | iv
Illustrations
Tables
1. SCC Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. SCC Master Registry Data as of October 2024 7
3. SCC Health Care Staffing Resources as of October 2024 8
4. SCC Results Compared With State HEDIS Scores 10
5. Access to Care 19
6. Other Tests Related to Access to Care 20
7. Diagnostic Services 25
8. Health Information Management 37
9. Other Tests Related to Health Information Management 38
10. Health Care Environment 44
11. Transfers 51
12. Other Tests Related to Transfers 52
13. Medication Management 59
14. Other Tests Related to Medication Management 60
15. Preventive Services 63
16. Specialized Medical Housing 81
17. Specialty Services 87
18. Other Tests Related to Specialty Services 88
19. Administrative Operations 91
A–1. Case Review Definitions 94
B–1. SCC Case Review Sample Sets 99
B–2. SCC Case Review Chronic Care Diagnoses 100
B–3. SCC Case Review Events by Program 101
B–4. SCC Case Review Sample Summary 101
Figures
A–1. Inspection Indicator Review Distribution for SCC 93
A–2. Case Review Testing 96
A–3. Compliance Sampling Methodology 97
Photographs
1. Indoor Waiting Area 40
2. Individual Waiting Modules 41
3. Expired Medical Supply Dated January 31, 2024 41
4. Long-Term Storage of Staff’s Food in the Medical Supply Storage Area 42
5. Staff’s Personal Items and Food Stored With Medical Supplies 42
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector General
(the OIG) is responsible for periodically reviewing and reporting on the delivery of the
ongoing medical care provided to incarcerated people1 in the California Department of
Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in Cycle 6,
including clinical case review and compliance testing. Together, these methods assess the
institution’s medical care on both individual and system levels by providing an accurate
assessment of how the institution’s health care systems function regarding patients with the
highest medical risk, who tend to access services at the highest rate. Through these methods,
the OIG evaluates the institution’s performance in providing sustainable, adequate care. We
continue to review institutional care using 15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection tool
(MIT). In addition, our clinicians complete document reviews of individual cases and
perform on-site inspections, which include interviews with staff. The OIG determines a total
compliance score for each applicable indicator and considers the MIT scores in the overall
conclusion of the institution’s compliance performance.
In conducting in-depth, quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course of
caring for a patient. In the event we find errors, we determine whether such errors were
clinically significant or led to a significantly increased risk of harm to the patient. At the same
time, our clinicians consider whether institutional medical processes led to identifying and
correcting individual or system errors, and we examine whether the institution’s medical
system mitigated the error.
The OIG rates each applicable indicator proficient, adequate, or inadequate, and considers
each rating in the overall conclusion of the institution’s health care performance. In contrast
to Cycle 6, the OIG will provide individual clinical case review ratings and compliance testing
scores in Cycle 7, rather than aggregate all findings into a single overall institution rating.
This change will clarify the distinctions between these differing quality measures and the
results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and the OIG
explicitly makes no determination regarding the constitutionality of care the department provides to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 2
As we did during Cycle 6, our office continues to inspect both those institutions remaining
under federal receivership and those delegated back to the department. There is no
difference in the standards used for assessing a delegated institution versus an institution
not yet delegated. At the time of the Cycle 7 inspection of Sierra Conservation Center (SCC),
the institution had been delegated back to the department by the receiver.
We completed our seventh inspection of the institution, and this report presents our
assessment of the health care provided at this institution during the inspection period from
March 2024 to August 2024.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between August 2023 and February 2024.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 3
Summary: Ratings and Scores
We completed the Cycle 7 inspection of Sierra Conservation Center (SCC) in March 2025. OIG
inspectors monitored the institution’s delivery of medical care that occurred between March
2024 and August 2024.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at SCC inadequate. quality at SCC inadequate.
OIG case review clinicians (a team of physicians and nurse consultants) reviewed 40 cases,
which contained 724 patient-related events. They performed quality control reviews; their
subsequent collective deliberations ensured consistency, accuracy, and thoroughness. Our
clinicians acknowledged institutional structures that catch and resolve mistakes throughout
the delivery of care. After examining the medical records, our clinicians completed a follow
up on-site inspection in March 2025, to verify their initial findings. OIG physicians rated the
quality of care for 20 comprehensive case reviews. Of these 20 cases, our physicians rated 11
adequate and nine inadequate.
To test the institution’s policy compliance, our compliance inspectors (a team of registered
nurses) monitored the institution’s compliance with its medical policies by answering a
standardized set of questions that measure specific elements of health care delivery. Our
compliance inspectors examined 351 patient records and 1,003 data points and used the
data to answer 84 policy questions. We also observed SCC’s processes during an on-site
inspection in October 2024.
The OIG then considered the results from both case review and compliance testing and drew
overall conclusions, which we report in 12 health care indicators.5
5 The indicators for Reception Center and Prenatal and Postpartum Care did not apply to SCC. During the OIG’s
Cycle 7 inspection period, Specialized Medical Housing was not sampled or tested.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 4
We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. SCC Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 5
Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies can be
minor or significant, depending on the severity of the deficiency. An adverse event occurs
when the deficiency caused harm to the patient. All major health care organizations identify
and track adverse events. We identify deficiencies and adverse events to highlight concerns
regarding the provision of care and for the benefit of the institution’s quality improvement
program to provide an impetus for improvement.6
The OIG found no adverse events at SCC during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed nine of the 12
indicators applicable to SCC. Of these nine indicators, OIG clinicians rated none proficient,
five adequate, and four inadequate. OIG physicians also rated the overall adequacy of care
for each of the 20 detailed case reviews they conducted. Of these 20 cases, 11 were adequate
and nine were inadequate. In reviewing the 724 events, we identified 303 deficiencies, 85 of
which we considered to be of such magnitude that, if left unaddressed, would likely
contribute to patient harm.
Our clinicians found the following strengths at SCC:
• Patients received good access to providers and nurses.
• Staff responded to emergencies promptly.
• Staff performed well in timely completing laboratory and radiology tests.
• Nurses performed well with administering prescribed medications to on-site
SCC patients.
Our clinicians found the following weaknesses at SCC:
• Nurses needed to improve in performing complete assessments, interventions,
and documentation for clinic, emergency care, and transfer patients.
• Providers needed improvement in poor assessment and decision-making,
particularly with more complex patients.
• Providers did not consistently communicate results to patients with complete
test result notification letters.
• The morning huddles process, through which medical staff share patient
information and prepare for the day’s upcoming medical encounters, revealed
6 For further discussion of an adverse event, see Table A–1.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 6
the patient care teams were unprepared and not fully knowledgeable of their
patients.
Compliance Testing Results
Our compliance inspectors assessed nine of the 12 indicators applicable to SCC. Of these nine
indicators, our compliance inspectors rated none proficient, four adequate, and five
inadequate. We solely tested policy compliance in Health Care Environment, Preventive
Services, and Administrative Operations because these indicators do not have a case
review component.
SCC showed a high rate of policy compliance in the following areas:
• SCC staff often ensured patients received diagnostic services within ordered
time frames, and providers timely reviewed and endorsed results.
• Staff performed very well in providing preventive services for patients, such as
influenza vaccination and colorectal cancer screenings. In addition, staff always
offered tuberculosis (TB) medications and almost always timely monitored
patients taking TB medications.
• Primary care providers usually evaluated their patients returning from outside
community hospitals and new patient arrivals within required time frames.
SCC showed a low rate of policy compliance in the following areas:
• SCC staff frequently did not maintain medication continuity for chronic-care
patients, patients discharged from the hospital, patients transferring in, or
patients who had a layover at SCC.
• Health care staff did not consistently follow universal hand hygiene precautions
during patient encounters.
• Providers did not often communicate results of diagnostic services timely with
complete test result notification letters. Most patient letters communicating
these results were missing the date of the diagnostic service, the date of the
results, or whether the results were within normal limits.
• Staff did not provide chronic-care and specialty-services provider follow-up
appointments within required time frames.
Institution-Specific Metrics
Sierra Conservation Center (SCC), located near Jamestown in Tuolumne County, was opened
in 1965. SCC provides housing, rehabilitative programs, and services for minimum- and
medium-custody incarcerated persons. It is one of the only two prisons in the state
responsible for the training and placement of incarcerated men in the conservation camp
program. SCC administers 20 male camps located from Central California to the California–
Mexico border. SCC houses incarcerated persons who are designated as low-to-medium
medical risk. These incarcerated persons have infrequent care needs that are mostly
managed at local community hospitals or through transfer from a camp back to the main SCC
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 7
facility for a higher level of care. The institution operates five medical clinics where medical
personnel handle nonurgent requests for medical services. SCC conducts screenings in its
receiving and release clinical area, treats patients who need urgent or emergent care in its
triage and treatment area, and treats patients requiring outpatient health services and
assistance with activities of daily living in the outpatient housing unit. SCC’s outpatient
housing unit was closed at the time of our review. California Correctional Health Care
Services has designated SCC as a basic care institution. Basic care institutions are located in
rural areas, away from tertiary care centers and specialty care providers whose services
would likely be used by higher-risk patients. Basic care institutions provide limited, specialty
medical services and consultation for a generally healthy patient population.
As of June 6, 2025, the department reported on its public tracker 45 percent of SCC’s
incarcerated population was fully vaccinated for COVID-19, while 53 percent of SCC’s staff
was fully vaccinated for COVID-19.7
On October 1, 2024, the Health Care Services Master Registry showed SCC had a total
population of 4,029. A breakdown of the medical risk level of SCC’s population as determined
by the department is set forth in Table 2 below.8
Table 2. SCC Master Registry Data as of October 2024
Medical Risk Level Number of Patients Percentage*
High 1 18 0.4%
High 2 42 1.0%
Medium 532 13.2%
Low 3,437 85.3%
Total 4,029 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from
the CCHCS Master Registry dated 10-1-24.
7 For more information, see the department’s statistics on its website page titled Population COVID‑19 Tracking.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 8
According to staffing data the OIG obtained from California Correctional Health Care Services
(CCHCS), as identified in Table 3 below, SCC had one vacant executive leadership position, 2.1
primary care provider vacancies, 2.7 nursing supervisor vacancies, and 9.5 nursing staff
vacancies.
Table 3. SCC Health Care Staffing Resources as of October 2024
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 5.0 6.5 10.7 57.1 79.3
Filled by Civil Service 4.0 4.4 8.0 47.6 64.0
Vacant 1.0 2.1 2.7 9.5 15.3
Percentage Filled by Civil Service 80.0% 67.7% 74.8% 83.4% 80.7%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0 0 0 0 0
Filled by Registry 0 0 0 0 0
Percentage Filled by Registry 0 0 0 0 0
Total Filled Positions 4.0 4.4 8.0 47.6 64.0
Total Percentage Filled 80.0% 67.7% 74.8% 83.4% 80.7%
Appointments in Last 12 Months 1.0 0 2.0 7.4 10.4
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 0 2.0 2.0
Adjusted Total: Filled Positions 4.0 4.4 8.0 45.6 62.0
Adjusted Total: Percentage Filled 80.0% 67.7% 74.8% 79.9% 78.2%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes the classifications of Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Notes: The OIG does not independently validate staffing data received from the department. Positions are based on
fractional time-base equivalents.
Source: Cycle 7 medical inspection preinspection questionnaire received on 10-1-24, from California Correctional
Health Care Services.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 9
Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted above, the OIG presents
selected measures from the Healthcare Effectiveness Data and Information Set (HEDIS) for
comparison purposes. The HEDIS is a set of standardized quantitative performance
measures designed by the National Committee for Quality Assurance to ensure the public has
the data it needs to compare the performance of health care plans. Because the Veterans
Administration no longer publishes its individual HEDIS scores, we removed them from our
comparison for Cycle 7. Likewise, Kaiser (commercial plan) no longer publishes HEDIS
scores. However, through the California Department of Health Care Services’ Medi‑Cal
Managed Care Technical Report, the OIG obtained California Medi-Cal and Kaiser Medi-Cal
HEDIS scores to use in conducting our analysis, and we present them here for comparison.
HEDIS Results
We considered SCC’s performance with population-based metrics to assess the macroscopic
view of the institution’s health care delivery. Currently, only two HEDIS measures are
available for comparative review: poor HbA1c control, which measures the percentage of
diabetic patients who have poor blood sugar control, and colorectal cancer screening rates
for patients ages 45 to 75. We list the applicable HEDIS measures in Table 4.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser Northern
California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—SCC’s percentage of
patients with poor HbA1c control was significantly lower at nine percent, indicating very
good performance on this measure.
Immunizations
Statewide comparative data were not available for immunization measures; however, we
include these data for informational purposes. SCC had a 40 percent influenza immunization
rate for adults 18 to 64 years old and an 83 percent influenza immunization rate for adults
65 years of age and older.9 The pneumococcal vaccination rate was 92 percent.10
Cancer Screening
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser Northern
California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—SCC’s percentage of
patients with colon cancer screening rate of 66 percent was higher than California Medi-Cal
but lower than California Kaiser NorCal and SoCal Medi-Cal.
9 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable result.
10 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines (PCV13, PCV15,
and PCV20), or 23 valent pneumococcal vaccine (PPSV23), depending on the patient’s medical conditions. For the
adult population, the influenza or pneumococcal vaccine may have been administered at a different institution other
than where the patient was housed during the inspection period.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 10
Table 4. SCC Results Compared With State HEDIS Scores
SCC California California
Kaiser Kaiser
Cycle 7 California NorCal SoCal
HEDIS Measure Results * Medi-Cal † Medi-Cal † Medi-Cal †
HbA1c Screening 100% – – –
Poor HbA1c Control (> 9.0%) ‡,§ 9% 33% 26% 19%
HbA1c Control (< 8.0%) ‡ 84% – – –
Blood Pressure Control (< 140/90) ‡ 97% – – –
Eye Examinations 84% – – –
Influenza – Adults (18 – 64) 40% – – –
Influenza – Adults (65 +) 83% – – –
Pneumococcal – Adults (65 +) 92% – – –
Colorectal Cancer Screening 66% 40% 71% 71%
Notes and Sources
* Unless otherwise stated, data were collected in October 2024 by reviewing medical records from a sample
of SCC’s population of applicable patients. These random statistical sample sizes were based on a 95 percent
confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication
Medi-Cal Managed Care Physical Health External Quality Review Technical Report, dated July 1, 2023 – June
30, 2024 (published April 2025); https://www.dhcs.ca.gov/dataandstats/reports/Documents/CA2023-24-
Medi-Cal-Managed-Care-Physical-Health-External-Quality-Review-Technical-Report-Vol1-F1.pdf.
‡ For this indicator, the entire applicable SCC population was tested.
§ For this measure only, a lower score is better.
Source: Institution information provided by the California Department of Corrections and Rehabilitation.
Health care plan data were obtained from the CCHCS Master Registry.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 11
Recommendations
As a result of our assessment of SCC’s performance, we offer the following recommendations
to the department:
Access to Care
• Nursing leadership should determine the root cause(s) of poor nurse triage of
health care services request forms (CDCR 7362) and implement remedial
measures as appropriate.
• Health care leadership should determine the root cause(s) of untimely provider
appointments for chronic care and provider follow-up appointments after
specialty services and implement remedial measures as appropriate.
• Health care leadership should develop and implement strategies to improve the
morning huddle process for the patient care teams.
Diagnostic Services
• Medical leadership should continue to study the implementation of their
proposed system improvements in patient letters and make any corrective
adjustments needed to ensure the new process is effective and improves the
rate of complete and clear communication to the patients.
Emergency Services
• Nursing leadership should develop strategies to ensure supervising registered
nurses (SRNs) complete thorough audits of all events that include emergency
medical responses and should implement remedial measures as appropriate.
• Nursing and medical leadership should develop strategies to ensure nursing and
provider clinical reviews identify all opportunities for improvement in provider
and nurse performance and should implement remedial measures as
appropriate.
• Medical leadership should develop strategies to ensure providers order
appropriate patient transportation to a higher level of care for emergent events
and should implement remedial measures as appropriate.
• The institution should consider replacing vital signs equipment with models
capable of synchronizing data with the electronic health record system
(EHRS).11
11 EHRS is the Electronic Health Records System. The department’s electronic health record system is used for
storing the patient’s medical history. The health care staff use the system to communicate. This record stays with the
patient throughout the patient’s time in department’s correctional system.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 12
Health Information Management
• Health care leadership should identify challenge(s) in the untimely receipt and
scanning of hospital as well as specialty reports and should implement
appropriate remedial measures.
Health Care Environment
• Medical and nursing leadership should determine the root cause(s) for staff not
following all required universal hand hygiene precautions and should
implement remedial measures as appropriate.
• Executive leadership should determine the root cause(s) for staff not following
equipment and medical supply management protocols and should implement
remedial measures as appropriate.
• Nursing leadership should determine the root cause(s) for staff not ensuring
EMRBs are regularly and properly inventoried, stocked, or sealed and should
implement appropriate remedial measures.
Transfers
• Nursing leadership should develop and implement strategies, such as internal
staff auditing, to ensure assessments are complete and thorough for patients
who transfer in, transfer out, or return from the hospital or emergency room.
• Medical and nursing leadership should develop and implement a process
between nursing and providers to ensure they promptly review all hospital
discharge recommendations and timely place orders.
Medication Management
• SCC leadership should develop and implement measures to ensure the fire camp
patients receive all medications without delay and ensure pharmacy staff
communicate with nurses when medications are returned to the institution.
Leadership should implement remedial measures as appropriate.
• SCC leadership should determine the challenges to providing medication
continuity for patients with chronic care medications, newly ordered
medications, transfer-in medications, and community hospital discharge
medications. Leadership should implement remedial measures as appropriate.
Preventative Services
• Health care leadership should determine the root cause(s) for challenges to
timely providing immunizations to chronic care patients and should implement
appropriate remedial measures.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 13
Nursing Performance
• Nursing leadership should identify the challenges preventing SCC nurses from
performing complete assessments and interventions and should implement
remedial measures as appropriate.
• Nursing leadership should develop and implement strategies, such as sick call
audits, to ensure supervisors evaluate the nursing triage process to confirm the
nurses properly assess patients’ requests and schedule patients with urgent or
emergent symptoms in an appropriate time frame. Leadership should
implement remedial measures as appropriate.
• SCC nursing and medical leadership should develop strategies to ensure
primary care huddles are thorough and comprehensive, and the care teams
address all pending or unresolved items. Leadership should implement
remedial measures as appropriate and educate all medical staff on proper
huddle expectations.
Provider Performance
• Medical leadership should identify the root cause(s) for poor provider care of
medically complex patients and should implement remedial measures as
appropriate.
• Medical leadership should develop and implement strategies to ensure patients
receive specialty services within priority time frames appropriate to their
medical conditions.
Specialty Services
• Health care leadership should determine the root cause(s) of untimely
preapproved specialty appointments for transfer-in patients and implement
appropriate remedial measures.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 14
Indicators
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing patients
with timely clinical appointments. Our inspectors reviewed scheduling and appointment
timeliness for newly arrived patients, sick calls, and nurse follow-up appointments. We
examined referrals to primary care providers, provider follow-ups, and specialists.
Furthermore, we evaluated the follow-up appointments for patients who received specialty
care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (73.2%)
In Cycle 7, case review found SCC provided acceptable access to care, as in Cycle 6. After staff
ordered appointments, they often occurred timely. Chronic-care appointments for patients
housed at SCC also occurred timely. In addition, hospital and triage and treatment area (TTA)
follow-ups as well as clinic appointments also occurred timely, once ordered. We found
providers sometimes ordered inappropriate specialty-referral priorities; however, this did
not significantly hinder access to specialty services. Although nurses performed poorly in
triaging sick calls, if an appointment was ordered, it usually occurred timely. Considering all
factors, the OIG rated the case review component of this indicator adequate.
Compliance showed SCC performed variably for this indicator. Staff performed excellently in
timely reviewing patient sick calls and often completed nurse face-to-face appointments
within the required time frame. Providers almost always timely completed appointments for
patients returning after hospitalizations and for newly transferred patients. However, staff
needed significant improvement in timely completing provider appointments for chronic
care patients and for patients returning after specialty services appointments. Based on the
overall Access to Care compliance score result, the OIG rated the compliance component of
this indicator inadequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 185 provider, nursing, urgent or emergent care (TTA), specialty, and
hospital events that required the institution to generate appointments. We identified 14
deficiencies directly relating to Access to Care, seven of which were significant.12
Access to Care Providers
SCC’s performance was mixed for access to providers. Compliance testing showed poor
performance with timely completion of provider chronic care follow-up appointments (MIT
1.001, 48.0%) but excellent performance with timely completion of nursing to primary care
provider referrals (MIT 1.005, 100%).
12 Access to care deficiencies occurred in cases 1, 8, 11-12, 14-16, 20-21, 23, and 34. Significant deficiencies
occurred in cases 12, 14-15, 21, and 34
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
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OIG clinicians identified six deficiencies in provider access, only one of which was significant
as follows:13
• In case 34, the sick call RN evaluated the patient and documented a plan to refer
the patient to a provider within 14 days; however, the RN did not order this
appointment within this timeframe.
Access to Clinic Nurses
Ensuring nurses timely receive, review, and triage patient sick calls is critical. SCC’s
performance varied in access to clinic nurses. Compliance testing showed nurses performed
excellently in triaging sick calls (MIT 1.003, 100%), and sufficiently in completing face-to-
face assessments (MIT 1.004, 81.3%). However, OIG clinicians found poor nursing access. We
reviewed 50 nursing sick call requests in 21 cases and identified 11 nursing performance
deficiencies in which SCC nurses did not appropriately triage sick calls or order needed
follow-up appointments, delaying medical care. Six of the 11 deficiencies were significant.14
In two deficiencies, nurses triaged health care services request forms and ordered
appointments correctly; however, staff did not schedule the appointments within compliance
time frames. The following deficiency was significant:
• In case 15, the RN reviewed a sick call request from the patient for possible side
effects from Lasix, a diuretic medication. His symptoms included excessive
urination, incontinence, and penile pain. The nurse documented the patient
should be seen; however, a nurse did not assess the patient and his symptoms
worsened, resulting in his transfer to the hospital three days later.
The remaining nine deficiencies related to poor nursing triage of medical requests for
services, five of which were significant. This led to the patients not being assessed by nurses
despite their medical need for care. We discuss further in the Nursing Performance
indicator.
Access to Specialty Services
Access to specialty services was good overall. Compliance testing revealed an excellent
completion rate of high-priority (MIT 14.001, 93.3%) and routine-priority (MIT 14.007,
93.3%) specialty service appointments. In addition, medium-priority specialty appointments
frequently occurred timely (MIT 14.004, 80.0%).
OIG clinicians identified a pattern of SCC providers ordering referrals for specialty services
with medically inappropriate time frame priorities; however, once providers ordered the
referrals, the referrals often occurred timely. We found six deficiencies, five of which were
clinically significant.15 We discuss the referral pattern further in the Provider Performance
and Specialty Services indicators.
13 Provider access deficiencies occurred in cases 8, 12, 16, 20, 23, and 34. A significant deficiency occurred in case
34.
14 Nurse sick call events occurred in cases 1-2, 10-15, 18, and 30-41. Deficiencies occurred in cases 2, 10-12, 14-15,
and 18. Significant deficiencies occurred in cases 2, 11,15, and 18.
15 Deficiencies occurred in cases 1, 12, 14, and 21. Significant deficiencies occurred in cases 12, 14, and 21.
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Cycle 7, Sierra Conservation Center | 16
Follow-Up After Specialty Services
Compliance testing revealed SCC needed improvement in timely provider follow-up
appointments after specialty services (MIT 1.008, 69.1%).
OIG clinicians identified four deficiencies in which providers did not timely evaluate patients
for scheduled specialty services follow-up appointments. Only one appointment was high
priority, and none were significant.16 All four appointments were “completed” in the medical
record as though the patient had been seen; however, none of the appointments occurred.
Follow-Up After Hospitalization
Compliance testing showed providers frequently followed up with their patients after
hospitalizations (MIT 1.007, 92.0%) within the required time frames. OIG clinicians did not
identify any access deficiencies with the provider follow-up appointments.
Follow-Up After Urgent or Emergent Care (TTA)
SCC providers generally evaluated their patients following a TTA event as medically
indicated. OIG clinicians reviewed 19 TTA events in which patients returned to the housing
units. Of those 19 TTA events, 11 primary care provider follow-up appointments occurred
between five and 14 days late. We identified no provider follow-up appointment deficiencies.
Follow-Up After Transferring into the SCC
Staff timely evaluated their patients after they transferred into SCC. Compliance testing
showed excellent access to clinicians for newly arrived patients (MIT 1.002, 95.0%). OIG
clinicians did not find any transfer-in nursing or provider access deficiencies.
Clinician On-Site Inspection
OIG clinicians spoke with SCC’s medical leadership, nursing leadership, and schedulers
regarding patients’ access to care. We also attended the morning huddles.
Leadership reported SCC had no specialized medical housing, but had three main on-site
clinics designated A, B, and C. SCC is the primary medical hub for 31 fire camps throughout
the state, which are owned and operated by CalFire. Due to the closure of California
Correctional Center, SCC received 15 northern camps from November to December 2022. The
fire camps house approximately 1,600 incarcerated persons at various locations throughout
the state.
Leadership stated the incarcerated persons at the fire camps are assigned to medical care at
one of two hubs, depending on their location: California Institute for Men (CIM) via
telemedicine for southern fire camp patients, or SCC. For routine medical care, the patients
are transported by custody from their camps to the closest medical hub, either CIM or SCC.
There, they are seen by providers, nursing staff, and laboratory staff, either in person or via
telemedicine. Transport occurs in custody vans that can hold only eight incarcerated persons,
limiting the number of patients who can be seen at one time at each location.
16 Follow-up provider deficiencies related to providers occurred in cases 12, 20, and 23.
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Leadership stated firefighters in the fire camps must meet certain criteria for “vigorous duty.”
Incarcerated camp support personnel must also meet full-duty criteria and be rated at no
more than medium medical risk. Some firefighters or camp support patients do require
periodic medical appointments, laboratories, and chronic medication administration.
Medical leadership stated chronic care appointment frequency is determined by the chronic
care registry and appointments are grouped by location in a rotational method.
Leadership reported the health care requests for services (Form 7362s) are available in fire
camps and described the sick call process. Completed 7362s are picked up weekly at fire
camps, instead of daily as is the practice in an institutional setting. Most of these are non-
symptomatic. An SCC RN triages the 7362s delivered to SCC on the weekly bus and routes
them to the appropriate department. SCC considers the day SCC receives the 7362 as the date
the patient completed the 7362, even if the patient submitted the 7362 six days prior. With
this process, the fire camp patients may not receive timely RN triage of their medical
requests, or do not receive the medical privacy of the 7362 lock boxes as at SCC.
MERT activations can occur anywhere in the state, and a designated number of medical
personnel, firefighters, and camp support personnel must immediately deploy to the disaster
area.17 SCC providers and nurses support the activation for maximum seven-day shifts. If
disaster support is required longer than seven days, additional medical staff will undertake
the next seven-day shift. This continues until the disaster ends. This may affect provider
availability at SCC, during the peak fire season. Providers stated they use satellite for internet
access while deployed so they can continue to support their patient panel at SCC, as well as
obtain camper histories in the event of an emergency. We discuss MERT further in the
Nursing Performance indicator.
OIG clinicians identified one provider who was responsible for “completing” specialty follow-
up appointments without evaluating the patient in person. At the on-site inspection, this
provider mentioned this was due to a process-knowledge deficit and received corrective
training prior to our inspection.
We observed morning huddles on all yards. The morning huddles are intended to function as
a daily meeting between all care staff to discuss, coordinate, and prioritize patient needs,
including medication renewals, overnight emergencies or events, and newly arrived patients.
Morning huddles also generally strategize resolutions for nursing, provider, and specialty
appointments that have past compliance deadlines. Appropriate staff attended the SCC
huddles; however, the huddle members did not exchange critical patient care information.
Instead, medical assistants or LVNs facilitated the huddles using a huddle report, which
involved them simply calling out a section of the huddle report, such as “medication
renewals,” then announcing only the number of patients listed under that section. The
huddle members did not discuss important information about any of the patients or any
medication details, and the SCC providers asked no questions. When OIG clinicians requested
further details on some of the patients, we found the staff members running the huddles
were not familiar with the patients, their medical issues, or the medical significance of their
entries on the daily huddle report. In the six huddles, we witnessed staff were unprepared
and unfamiliar with their patients.
17 MERT stands for Medical Expedition Response Team, which is a specialized unit of medical personnel
that responds to medical emergencies during natural disasters or highly hazardous disasters.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
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Compliance Testing Results
None of the four housing units randomly tested at the time of inspection had access to health
care services request forms (CDCR 7362) (MIT 1.101, zero). In four housing units, custody
officers did not have a system in place for restocking the forms. Custody officers reported
they either relied on medical staff to replenish these forms in the housing units or printed a
copy from their own computers, which meant they did not use the required triplicate forms.
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Compliance Score Results
Table 5. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent chronic
care visit within the health care guideline’s maximum allowable interval or 12 13 0 48.0%
within the ordered time frame, whichever is shorter? (1.001)
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 19 1 5 95.0%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
32 0 0 100%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
26 6 0 81.3%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
15 0 17 100%
maximum allowable time or the ordered time frame, whichever is the
shorter? (1.005)
Sick call follow-up appointments: If the primary care provider ordered a
follow-up sick call appointment, did it take place within the time frame 0 0 32 N/A
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
23 2 0 92.0%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
29 13 3 69.1%
occur within required time frames? (1.008) *
Clinical appointments: Do patients have a standardized process to obtain
0 4 0 0
and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 73.2%
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Table 6. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the nurse
referred the patient to a provider, was the patient seen within the required N/A N/A N/A N/A
time frame? (12.003)
For patients received from a county jail: Did the patient receive a history
and physical by a primary care provider within seven calendar days (prior to N/A N/A N/A N/A
07/2022) or five working days (effective 07/2022)? (12.004)
Was a written history and physical examination completed within the
N/A N/A N/A N/A
required time frame? (13.002)
Did the patient receive the high-priority specialty service within 14 calendar
days of the primary care provider order or the Physician Request for 14 1 0 93.3%
Service? (14.001)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 8 1 6 88.9%
provider? (14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or the Physician Request 12 3 0 80.0%
for Service? (14.004)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 7 0 8 100%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 14 1 0 93.3%
for Service? (14.007)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care 9 1 5 90.0%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Sierra Conservation Center | 21
Recommendations
• Nursing leadership should determine the root cause(s) of poor nurse triage of
health care services request forms (CDCR 7362) and implement remedial
measures as appropriate.
• Health care leadership should determine the root cause(s) of untimely provider
appointments for chronic care and provider follow-up appointments after
specialty services and implement remedial measures as appropriate.
• Health care leadership should develop and implement strategies to improve the
morning huddle process for the patient care teams.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
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Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s performance in timely completing
radiology, laboratory, and pathology tests. Our inspectors determined whether the institution
properly retrieved the resultant reports and whether providers reviewed the results
correctly. In addition, in Cycle 7, we examined the institution’s performance in timely
completing and reviewing immediate (STAT) laboratory tests.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (75.8%)
In this cycle, case review found SCC performed satisfactorily in diagnostic services,
consistent with Cycle 6. Staff timely completed diagnostic services both for on-site and camp
patients. Radiology staff also completed these tests within ordered timelines. However, we
identified deficiencies in patient notification letter generation and missing off-site pathology
reports. After considering all factors, the OIG rated the case review component of this
indicator adequate.
SCC’s performance in compliance testing was mixed in this indicator. Staff generally
completed diagnostic services timely. Providers also performed excellently in reviewing and
endorsing diagnostic test results within the required time frames. In contrast, providers
needed improvement in generating complete patient test result notification letters with all
required elements. Based on the overall Diagnostic Services compliance score result, the
OIG rated the compliance component of this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 114 diagnostic events and identified 33 deficiencies, one of which
was significant. Of these 33 deficiencies, 30 related to health information management. Of
the remaining three deficiencies, two related to not sending patient test result notification
letters and one related to a nurse not consulting with providers about an abnormal test
result. We found no deficiencies related to incomplete or delayed diagnostic tests.18
Test Completion
Compliance testing found SCC performed very well in completing radiology services (MIT
2.001, 90.0%) and sufficiently in completing laboratory tests (MIT 2.004, 80.0%). OIG
clinicians found no deficiencies with laboratory or radiology test completion.
Neither case review nor compliance testing had any STAT laboratory tests in their samples to
review (MIT 2.007, NA).
18 Deficiencies occurred in cases 1, 9-10, 12-15, 18, and 20-23. The significant deficiency occurred in case 12.
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
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Please see the Clinician On-Site Inspection section below for further discussion on
diagnostic studies.
Health Information Management
SCC providers reviewed and endorsed laboratory and radiology studies well; however,
communicating results with complete test result notification letters to the patients was poor.
Compliance testing showed providers performed excellently in the timely review of
radiology reports, laboratory results, and pathology results (MIT 2.002, 100%, MIT 2.005,
100%, and MIT 2.011, 100%.). Staff also performed well with retrieving pathology reports
within required time frames (MIT 2.010, 80.0%). However, providers performed poorly in
communicating with complete patient test result notification letters for radiology results
(MIT 2.003, 40.0%), laboratory results (MIT 2.006, 62.5%), and pathology results (MIT
2.012, 30.0%).
OIG clinicians reviewed 114 diagnostic events, none of which contained STAT test or on-site
biopsies with pathology. We identified 33 deficiencies, 32 of which related to omitted
elements in patient results letters or missing patient results letters.19 We identified one
significant deficiency as follows:
• In case 12, the patient’s normal EKG was scanned into the patient’s medical record;
however, another patient’s abnormal EKG was also erroneously included.
OIG clinicians identified deficiencies with missing off-site pathology reports which we
discuss in more detail in the Health Information Management indicator.
Clinician On-Site Inspection
OIG clinicians met with diagnostic, HIM, and medical leadership as well as staff to discuss
diagnostic services. Medical leadership reported STAT laboratory tests were not available at
SCC or at fire camps; therefore, none were ordered. If STAT laboratory tests were needed,
patients would have to be sent to the local hospital for further evaluation.
Diagnostic leadership reported having on-site x-ray services, and specialty CT, MRI, and
ultrasound imaging services.20 Staff completed x-rays on-site for patients housed at SCC as
well as for non-emergent fire camp patients as needed. An imaging vendor provided mobile
CTs, MRIs, ultrasounds, and FibroScans for SCC.21 The CTs and MRIs were usually completed
monthly, and the imaging schedule was available one year in advance.
Diagnostics leadership and the laboratory assistants scheduled the on-site and fire camp
patient laboratory tests. They reported most new SCC patients arrive in A and B yards, where
medical staff draw additional screening laboratory tests to complement the initial intake
screening laboratory tests drawn at the reception center. From those yards, medical staff
19 Diagnostic HIM deficiencies occurred in cases 1, 9-10, 12, 15, 18, and 21-23. The significant deficiency occurred in
case 12.
20 A CT is a computed, or computerized, tomography scan while an MRI is a magnetic resonance imaging scan. Both
create detailed images of the organs and tissues to detect diseases and abnormalities.
21 A FibroScan is a diagnostic imaging scan used to evaluate for liver scarring and fatty changes from liver disease.
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Cycle 7, Sierra Conservation Center | 24
evaluate and approve some patients to go to one of the 31 fire camps locations throughout
California.
Leadership reported the approximately 1,600 fire camp incarcerated persons may be
deployed at any time to support CalFire emergencies such as fire, snow removal, or sand
bagging efforts anywhere in the state. For instance, leadership mentioned approximately
1,000 incarcerated persons were deployed earlier this year to southern California to assist in
the fires that occurred there, requiring rescheduling of tests.
Leadership stated the fire camps may affect timely completion of laboratory tests. Medical
hubs are set up across the state to accommodate the most distant fire camp patients. Most
incarcerated persons assigned to the fire camps are low risk medical, requiring less frequent
laboratory blood draws than higher medical risk patients, but laboratory studies are
sometimes necessary. Laboratory technicians stated they travel to two fire camp hubs per
week for scheduled laboratory draws. Transport from the fire camps to the hubs is limited to
eight incarcerated persons due to the custody transport van passenger capacity.
Leadership stated providing timely radiology services for fire camp patients may also be a
challenge for several reasons. Due to the distance between most fire camps and SCC, fire
camp patients scheduled for imaging usually must stay at SCC at least overnight. Medical
leadership mentioned fire camp patients will frequently refuse imaging studies because of
the yard politics and high risk of violence. When a new patient or returning fire camp patient
arrives at SCC, informal incarcerated yard leadership requires the patient to make “payment”
or physically fight to protect themselves. Leadership and staff reported most fire camp
patients would choose to avoid the required overnight stay to complete the studies, even if
refusing the imaging creates a high medical risk. As discussed further below in the Specialty
Services indicator, medical leadership stated they are piloting a program where distant fire
camp patients can temporarily house at a closer fire camp, then transport to SCC only for the
day of testing, rather than housing at SCC overnight.
The Chief Physician and Surgeon (CP&S) demonstrated a new patient diagnostic results
notification letter system that included all CCHCS required components in the letters.
According to leadership, this system may reduce the number of diagnostic HIM deficiencies
related to incomplete patient notification letters. Upon provider endorsement, the system
will generate standardized result letters for the 30 most common laboratory tests. Providers
can still generate personalized responses; however, they reported this will create additional
letters, which may cause patient confusion.
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Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
9 1 0 90.0%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
10 0 0 100%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
4 6 0 40.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
8 2 0 80.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
10 0 0 100%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
5 3 2 62.5%
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
N/A N/A N/A N/A
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frames? (2.008)
Laboratory: Did the health care provider endorse the STAT laboratory
N/A N/A N/A N/A
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within the
8 2 0 80.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
3 7 0 30.0%
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 75.8%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should continue to study the implementation of their
proposed system improvements in patient letters and make any corrective
adjustments needed to ensure the new process is effective and improves the
rate of complete and clear communication to the patients.
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Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed emergency medical services by examining the timeliness and
appropriateness of clinical decisions made during medical emergencies. Our evaluation
included examining the emergency medical response, cardiopulmonary resuscitation (CPR)
quality, triage and treatment area (TTA) care, provider performance, and nursing
performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services. The
OIG assessed the institution’s emergency services solely through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
In this cycle, case review found SCC performed poorly with emergency services. Compared
with Cycle 6, we identified more overall deficiencies as well as more significant deficiencies.
Although emergency medical response times were generally prompt, and medical
responders usually requested emergency medical services quickly, nurses often did not
thoroughly assess symptoms or initiate appropriate interventions. SCC providers also
completed poor patient assessments, missed documentation, and initiated insufficient or
inappropriate plans of care. Additionally, while SCC conducted clinical reviews when patients
had unscheduled higher level of care transfers, the medical and nursing leadership did not
identify opportunities for improvement for their staff. Overall, SCC had systemic issues in
their emergency provider and nursing care and did not have sufficient mechanisms in place
to identify and address individual and system deficits. Taking all factors into consideration,
the OIG rated this indicator inadequate.
Case Review Results
We reviewed 40 urgent and emergent events and found 58 emergency care deficiencies. Of
these 58 deficiencies, 18 were significant.22
Emergency Medical Response
SCC performed excellently with emergency medical response times. We reviewed 29
emergency medical events in which custody staff and nurses responded.23 We found custody
and medical staff responded promptly to emergencies throughout the institution and
initiated emergency medical services (EMS) promptly; however, one opportunity for
improvement is detailed below:
• In case 13, the patient exhibited signs of a stroke. The medical staff thought EMS
had been requested; however, after waiting 42 minutes, EMS still had not
22 Deficiencies occurred in case 2-4, 6, 11-13, 15, 17, 18, 20, 21, and 23. Significant deficiencies occurred in cases 2-
4, 6, 13, 15, 17, and 20.
23 Emergency medical responses occurred in cases 1-4, 6, 12-15, 17, 18, and 20.
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arrived. Subsequently, a TTA nurse initiated a new request, which prompted
EMS’s response to SCC.
Cardiopulmonary Resuscitation Quality
During this period, we reviewed two cases in which staff initiated CPR.24 In both cases,
custody staff initiated CPR, nurses responded promptly, and staff timely requested EMS;
however, nurses did not provide sufficient interventions. Two examples are below:
• In case 3, SCC custody and nursing staff performed CPR for eight minutes and
attached an automated external defibrillator (AED), which delivered a shock.25
Nursing staff also administered two doses of naloxone.26 The patient had a
return of spontaneous circulation (ROSC) but remained unresponsive.27 The
nurse did not administer additional doses of naloxone for the unconscious
patient with suspected opioid overdose, as per nursing protocol.
• In case 4, the nurse documented the patient had shallow respirations and was
only breathing four times per minute; however, the nurse did not continue
providing positive pressure ventilation.28 Instead, the nurse provided only two
rescue breaths and then applied a non-rebreather mask, which did not provide
adequate oxygenation.
Provider Performance
OIG clinicians identified 21 provider performance deficiencies, seven of which were
significant.29 Thirteen deficiencies related to poor provider assessment and decision making.
Deficiencies included providers not documenting progress notes to include their
assessments or patients’ plans of care. Additionally, nurses consulted providers about
patients, but providers sometimes did not document this communication. The following are
examples:
• In case 15, a provider evaluated the patient, who had a history of atrial
fibrillation and heart failure, for shortness of breath with exertion.30 The
provider did not check the patient’s oxygen saturation with exertion.
Furthermore, the provider did not consider other possible reasons for the
patient’s shortness of breath. Instead, the provider concluded the patient was
stable and discharged him to his housing unit. The patient’s condition worsened
24 CPR occurred in cases 3 and 4.
25 An automated external defibrillator (AED) is a portable device used to deliver an electric shock to the heart when
it detects an abnormal heart rhythm.
26 Naloxone is a medication used for emergency treatment of known or suspected opioid overdose. According to the
manufacturer, nasal naloxone doses can be safely administered every two to three minutes. CCHCS emergency
medical training allows nurses to administer five nasal naloxone doses when an opioid overdose is suspected.
27 Return of spontaneous circulation (ROSC) is the resumption of a sustained heart rhythm that perfuses the body
after cardiac arrest. Clinically, when ROSC occurs, the health care provider will check for a central arterial pulse.
28 Positive pressure ventilation is a method to deliver pressurized air or oxygen into the lungs for patients who
cannot breathe on their own.
29 Deficiencies occurred in cases 2, 11, 12, 15, 17, 18, 20, 21, and 23. Significant deficiencies occurred in cases 2, 15,
17, and 20.
30 Atrial fibrillation is a medical condition in which the heart chamber contracts abnormally, which can be life-threatening and
require treatment.
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and three days later, a different provider evaluated the patient for shortness of
breath. The second provider again did not perform a thorough examination and
did not pursue further testing. Instead, the provider discharged the patient back
to his housing unit. The patient continued to worsen and four days later,
complained of rectal bleeding, severe shortness of breath, and chest pain.
Subsequently, the patient was transferred to a community hospital, where he
was admitted and received a blood transfusion.
• In case 17, the provider evaluated the patient, who complained of abdominal
pain, nausea, and vomiting for several days. The provider ordered the patient be
transported to a community hospital for further evaluation; however, the
provider did not order ambulance transportation. Instead, the provider ordered
custody staff transport the patient via state vehicle, which was inappropriate for
the patient’s clinical condition.
• In case 20, a nurse consulted a provider regarding a patient with a traumatic
hand injury. The provider did not document a progress note and did not order
an x-ray to occur on the same day. Instead, the provider ordered the x-ray to
occur within 14 days and did not order a follow-up with the patient.
• In case 23, a nurse consulted a provider about the patient, who recently had
surgery. The provider ordered a new medication but did not document a
progress note. We identified a similar pattern of providers not documenting
pertinent nurse co-consultations with clinically relevant information in the
EHRS in cases 2, 12, 17, 18, and 20.
Nursing Performance
SCC nurses had mixed performance in providing emergency services. Nurses responded
promptly to medical emergencies and usually consulted a provider when warranted.
However, when patients’ symptoms required a thorough nursing assessment, the nurses
often did not fully assess the symptoms or initiate necessary interventions. The following are
examples:
• In case 2, the patient had cardiac risk factors and complained of chest pain. TTA
nurses identified the patient had a severely low heart rate; however, nurses
administered nitroglycerin, which could have caused the patient’s heart rate to
further decrease.31 Additionally, the nurse initiated the chest pain nursing
protocol but delayed administering aspirin for 20 minutes.32
• In case 15, the patient had a history of heart failure and had recently returned to
SCC after hemorrhoid surgery. Nurses responded to the patient’s complaints for
difficulty breathing and pain. The nurses documented the patient’s respiratory
rate was slightly high at 24 breaths per minute. Also, the nurses documented the
patient had swelling in both legs, a delayed capillary refill, and irregular labored
31 Nitroglycerin is a medication that dilates blood vessels to increase blood flow to the heart.
32 Aspirin has a blood-thinning effect and can be used to treat certain heart disease.
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breathing with diminished lung sounds.33 However, the nurse did not reassess
these abnormal findings before discharging the patient.
Nursing Documentation
OIG clinicians found SCC nurses rarely documented details of the information relayed to and
received from providers. Moreover, on occasion, nurses inconsistently documented timelines,
interventions, and their patients’ clinical presentations. The following are examples:
• In case 3, the first medical responder licensed vocational nurse (LVN) arrived at
the patient’s location as CPR was in progress. The LVN documented oxygen
delivery via non-rebreather mask; however, the TTA RN documented oxygen
was delivered via a bag-valve mask.34
• In case 12, this patient transferred to a community emergency room for
evaluation of rectal bleeding and symptomatic anemia. The TTA RN documented
the patient had shortness of breath and was lightheaded, but the provider on
call did not document being notified of these symptoms. In contrast, the
provider documented the patient was not short of breath, had no additional
bleeding, and had no lightheadedness.
Emergency Medical Response Review Committee
Compliance testing showed the Emergency Medical Response Review Committee at SCC
frequently did not review emergency events timely, did not review events at all, or did not
fully complete the incident package (MIT 15.003, 33.3%). OIG clinicians found, when patients
transferred to a higher level of care, supervising registered nurses (SRNs) always completed
the Emergency Response and Unscheduled Transport Event Checklist form, and designated
nursing and medical leadership also conducted clinical reviews. However, OIG clinicians
reviewed 19 events that warranted clinical reviews and identified opportunities for
improvement in 13 events. SCC’s clinical reviews only identified one of the 13 opportunities
for improvement.35 The following cases provide examples:
• In case 15, on two separate events, the patient was transferred to a community
emergency room for evaluation of shortness of breath. In these events, we
identified opportunities for improvement for both the nursing and provider
interventions; however, SCC nursing and medical leadership did not identify any
of these same opportunities during their clinical reviews.
• In case 17, nursing and medical leadership conducted a clinical review for the
patient, who transferred to a community emergency room for abdominal pain
and tenderness. SCC did not identify opportunities for improvement for nurses
in monitoring the patient’s vital signs and severity of abdominal pain. Moreover,
the review did not identify the concern that an SCC provider ordered custody
33 Delayed capillary refill means it takes longer than usual for the blood to return to the skin in the fingers or toes
after pressing on them. This can be a sign of poor blood flow and may lead to further complications.
34 A non-rebreather mask is an oxygen mask that delivers high concentrations of oxygen and is used when a person
can breathe on their own but needs a lot of oxygen quicky. A bag valve mask (BVM), also known as an ambu bag, is a
hand-held device used to provide rescue breathing when someone is not breathing on their own.
35 SCC’s nursing and medical leadership did not identify opportunities for improvement in cases 2, 3, 4, 6, 12, 13, 15,
17, and 18.
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staff to transport the patient to the community emergency room via a state
vehicle despite the patient’s condition warranting EMS monitoring and
ambulance transportation.
Clinician On-Site Inspection
At SCC, the TTA is located in the A/B facility. The TTA has three examination room bays and a
nursing station. Collectively, the bays had a defibrillator, EKG machine, scale, treatment carts,
gurneys, and vital sign monitors. Unfortunately, the nurses could not document into the
EHRS at the point of service because of poor computer battery life and mobile workstations
that did not have computers. Subsequently, we learned the nurses must return to the nursing
station to chart all information into their patients’ medical records. Additionally, SCC’s vital
sign machines do not automatically record to the corresponding patient record. Instead,
nurses must manually enter all vital signs before the machine is powered off, or the data will
be automatically deleted.
We learned, on the morning and afternoon shifts, two RNs staff the TTA, and the medication
administration LVNs serve as the first medical responders (FMR). On the evening shift, one
TTA RN is the FMR for A/B facility and one TTA RN remains in the C facility medical clinic to
facilitate prompt emergency response. Although a TTA RN always responds to medical
alarms, we learned they do so on foot with an emergency response bag, which could take
longer to arrive to the patient. In some cases, when requested, SCC’s local fire department
responded via ambulance. During business days and hours, an on-site medical provider is
assigned to assist the TTA; outside of these hours, an on-call provider is available via
telephone.
During OIG clinicians’ interviews with the TTA RNs, we learned, in addition to responding to
institutional alarms, the TTA RNs assessed patients returning from off-site specialist
appointments, community hospitals, and emergency room encounters. An additional
responsibility for the TTA RN included triaging medical concerns received from the fire
camps. The nurses explained, when fire camp patients required immediate care, custody staff
would activate EMS or transport patients to a local emergency room. The nursing staff
indicated they documented all communication with the fire camps in a call log created in
Microsoft Excel on the institutional computer shared drive.
The Chief Nurse Executive (CNE) shared with the OIG clinicians the SRNs reviewed each
patient encounter only if it resulted in a higher level of care transfer. The CNE indicated
institutional medical alarms that did not result in a higher level of care were not subject to
this formal review process. Additionally, nursing leadership did not conduct clinical reviews
for TTA nursing encounters. The CNE planned this year to initiate a formal review process for
these encounters.
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Recommendations
• Nursing leadership should develop strategies to ensure supervising registered
nurses (SRNs) complete thorough audits of all events that include emergency
medical responses and should implement remedial measures as appropriate.
• Nursing and medical leadership should develop strategies to ensure nursing and
provider clinical reviews identify all opportunities for improvement in provider
and nurse performance and should implement remedial measures as
appropriate.
• Medical leadership should develop strategies to ensure providers order
appropriate patient transportation to a higher level of care for emergent events
and should implement remedial measures as appropriate.
• The institution should consider replacing vital signs equipment with models
capable of synchronizing data with the electronic health record system (EHRS).
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Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link in
high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (72.6%)
Case review found SCC performed acceptably in health information management. Staff
usually retrieved and scanned, and providers generally endorsed, diagnostic results timely.
However, we identified some incomplete hospital records, missing off-site pathology reports,
and errors regarding specialty service consultation reports. Considering all factors, the OIG
rated the case review component of this indicator adequate.
Compliance testing showed SCC needed improvement in this indicator. Staff did always scan
patient sick call requests timely, and they mostly retrieved and scanned hospital records and
specialty reports within the required time frames. However, SCC needed improvement in
timely obtaining and endorsing hospital reports as well as properly scanning and labeling
medical records into the correct patient files. Based on the overall Health Information
Management compliance score result, the OIG rated the compliance component of this
indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 728 events and found 51 deficiencies related to health information
management. Of these 51 deficiencies, eight were significant.36
Hospital Discharge Reports
Compliance testing showed SCC staff performed sufficiently in retrieving and scanning
hospital discharge records into the EHRS within the required time frames (MIT 4.003,
75.0%). However, staff needed improvement in obtaining hospital discharge reports with key
elements and reviewing them timely (MIT 4.005, 52.0%).
OIG clinicians reviewed 26 off-site emergency department and hospital encounters. SCC
usually retrieved and scanned hospital records into the EHRS, and providers endorsed them
36 Deficiencies occurred in cases 1-2, 9-15, 18, and 20-23. Significant deficiencies occurred in cases 2, 11-12, 15, 17,
and 21.
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timely. However, OIG clinicians identified five deficiencies with discharge and hospital record
retrieval, three of which were significant as follows:37
• In case 2, when the provider evaluated the patient four days after hospital
discharge for emergency small bowel resection, the record contained no
hospital documentation from either of the hospitals involved in the patient’s
care during this event. Because of this missing information, the provider was
unable to adequately assess and treat the patient at the follow-up appointment.
Staff scanned the hospital records two days late.
• In case 12, while hospitalized, the patient had a flexible sigmoidoscopy with
biopsies completed for uncontrolled ulcerative colitis and severe anemia.38 SCC
staff retrieved the biopsy results nearly one month late. This increased the
patient’s risk for delayed diagnosis and treatment.
• In case 17, the patient had surgery to remove two intestinal segments, which
were sent to the hospital laboratory for analysis; however, HIM staff never
obtained the pathology report on the specimens. This increased the patient’s
risk for a missed diagnosis and treatment.
Specialty Reports
Compliance testing showed SCC performed satisfactorily in timely receiving and endorsing
medium-priority reports (MIT 14.005, 76.9%). In contrast, SCC needed improvement in
scanning of specialty documents within required time frames (MIT 4.002, 73.3%). SCC also
needed improvement in timely receiving and endorsing high-priority specialty reports (MIT
14.002, 73.3%) and performed poorly in timely receiving and endorsing routine-priority
reports (MIT 14.008, 53.3%).
OIG clinicians reviewed 74 specialty consultation reports and identified 15 deficiencies,
three of which were significant.39 Eight deficiencies related to misfiled or mislabeled
specialty documents, five deficiencies related to specialty reports scanned late into the EHRS,
and two deficiencies related to late or missing provider endorsements. The following are
significant deficiencies:
• In case 12, SCC staff scanned a parathyroid gland scan result into the EHRS
nearly one month late.40 This delay was significant because the results of this
test were necessary for the ENT specialist to review to decide on surgical
treatment.41
• In case 15, after a virtual physical therapy appointment, the LVN messaged the
provider stating the appointment occurred and to follow up on the specialist’s
37 HIM hospital deficiencies occurred in cases 2, 12, 15, and 17.
38 Flexible sigmoidoscopy is a procedure using a flexible lighted tube to visualize inside the rectum and lower large
intestines. Ulcerative colitis is a disease with chronic inflammation and ulcers in the intestines.
39 Deficiencies occurred in cases 12-15 and 20-22. Significant deficiencies occurred in cases 12, 15, and 21.
40 The parathyroid gland is located in the neck and regulates calcium, phosphorous, and vitamin D levels.
41 An ENT specialist is an Ear Nose and Throat specialist.
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recommendations; however, staff scanned the physical therapy report over five
months later.
• In case 21, an ENT specialist collected neck wound cultures on the patient’s
recurrent neck abscesses. The results showed bacteria with multiple drug
resistances. SSC staff obtained the results eight days late and then included
them as part of another hospital record. This may have affected the patient’s
treatment plan and outcome.
OIG clinicians found, once reports were scanned, providers often endorsed them within
required time frames.
Diagnostic Reports
SCC’s performance in managing diagnostic reports was mixed. Compliance showed providers
always timely endorsed radiology, laboratory, and pathology results within specified time
frames (MIT 2.002, 100%, MIT 2.005, 100%, and MIT 2.011, 100%). Staff often received
pathology reports timely (MIT 2.010, 80.0%); however, providers only sporadically
communicated pathology results to patients with complete notification letters (MIT 2.012,
30.0%) within specified time frames. OIG clinicians found providers endorsed diagnostic
studies timely and often communicated the results to patients with notification letters;
however, the notification letters frequently lacked all CCHCS required components. OIG
clinicians also found HIM staff did not always timely retrieve the pathology reports for
procedures completed offsite.
Neither case review nor compliance testing had any STAT laboratory tests in their samples to
review (MIT 2.007, N/A).
Please refer to the Diagnostic Services indicator for further details.
Urgent and Emergent Records
OIG clinicians reviewed 40 emergency care events and found SCC nurses and providers
usually documented these events adequately. We identified six provider performance
deficiencies for missing or incomplete emergency documentation, two of which were
significant.42 We discuss nursing and provider performance deficiencies further in the
Emergency Services, Nursing Performance and Provider Performance indicators.
Scanning Performance
SCC’s performance in scanning varied. Compliance testing showed staff always scanned
health care services request forms into the EHRS within required time frames (MIT 4.001,
100%) and performed satisfactorily in scanning community hospital discharge documents
(MIT 4.003, 75.0%). However, SCC needed improvement in properly scanning, labelling, and
including medical records in the correct patients’ files (MIT 4.004, 62.5%). OIG clinicians
reviewed over 39 encounters requiring HIM to scan, label, and file records. We identified
42 Urgent and Emergent provider HIM deficiencies occurred in cases 2, 12, 15, 17 and 23. Two significant
deficiencies occurred in case 2.
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nine deficiencies, only one of which was significant.43 We also discuss these in the
Diagnostic Services and Specialty Services indicators.
Clinician On-Site Inspection
We discussed health information management processes with SCC HIM leadership, medical
leadership, office technicians, nurses, providers, and ancillary staff.
HIM leadership reported only having approximately 50 percent of the allotted health records
technicians during the review period. Recruitment efforts were ongoing; however, they had
received very little interest in the positions. One reason given for recruitment difficulties was
no clear promotional path past Health Records Technician II. After a long recruitment
process, one additional staff was hired in December 2024.
HIM leadership reported they historically audit each other’s work; however, due to short
staffing, this was not possible. Leadership stated this may have contributed to the filing and
labelling errors found in our review and stated the auditing process would be
reimplemented since the additional December staff hire.
HIM leadership stated HIM is responsible for obtaining off-site specialty, hospital, emergency,
and imaging documents. They reported having direct electronic access to one outside facility
with two more in process. HIM expressed having experienced difficultly obtaining outside
records from facilities without direct electronic access. For those facilities, HIM must fax and
email requests for records, then follow up with phone calls. Telemedicine nurses are
responsible for obtaining telemedicine specialty reports that HIM scan upon receipt. On
August 19, 2024, HIM received access to the MedWeb database system for retrieving missing
telemedicine specialty reports.
HIM, diagnostics, medical leadership, and staff stated, in July 2024, CCHCS headquarters
implemented an improved pathology report retrieval process. Leadership reported HIM or
diagnostic staff were previously responsible for identifying and retrieving outstanding
pathology reports. The new pathology report retrieval process requires providers to order
retrieval of outstanding pathology reports after their review of specialty, hospital, or on-site
records. HIM will then obtain, scan, and forward the report to the provider for review and
endorsement.
Staff reported the providers supporting the three northern fire camp hubs may have little or
no internet connectivity during fire camp on-site clinics. This may limit access to real-time
updated information in the EHRS.
43 General scanning deficiencies occurred in cases 12-15, and 20-21. A significant deficiency occurred in case 12.
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Compliance Score Results
Table 8. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s electronic
20 0 12 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
22 8 15 73.3%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 15 5 5 75.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
15 9 0 62.5%
and included in the correct patients’ files? (4.004)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 13 12 0 52.0%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 72.6%
Source: The Office of the Inspector General medical inspection results.
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Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
10 0 0 100%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
10 0 0 100%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
8 2 0 80.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
3 7 0 30.0%
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 11 4 0 73.3%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 10 3 2 76.9%
frame? (14.005)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 8 7 0 53.3%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Health care leadership should identify challenge(s) in the untimely receipt and
scanning of hospital as well as specialty reports and should implement
appropriate remedial measures.
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Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection control,
sanitation procedures, medical supplies, equipment management, and examination rooms.
Inspectors also tested clinics’ performance in maintaining auditory and visual privacy for
clinical encounters. Compliance inspectors asked the institution’s health care administrators
to comment on their facility’s infrastructure and its ability to support health care operations.
The OIG rated this indicator solely on the compliance score. Our case review clinicians do not
rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining the
institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Adequate (75.0%)
Overall, SCC performed acceptably with respect to its health care environment. Staff always
appropriately cleaned, sterilized, and disinfected all clinical areas or medical equipment.
Staff also excellently stored medical supplies in the medical warehouse. However, SCC
needed improvement in several areas. Medical supplies storage areas in the clinics contained
disorganized, unidentified, or inaccurately labeled medical supplies. Some clinics did not
meet the requirements for essential core medical equipment and supplies In addition, staff
did not always document the automated external defibrillator (AED) performance test
results within the last 30 days and did not regularly
sanitize or wash their hands during patient
encounters. Furthermore, emergency medical
response bags (EMRBs) contained compromised
medical supply packaging or had not been properly
inventoried. Based on the overall Health Care
Environment compliance score result, the OIG
rated this indicator adequate.
Compliance Testing Results
Waiting Areas
We inspected only indoor waiting areas as SCC had
no outdoor waiting areas. Health care and custody
staff reported existing waiting areas contained
sufficient seating capacity (see Photo 1, right).
Patients waited either in the clinic waiting area or
in individual modules (see Photo 2, below). During
Photo 1. Indoor waiting area (photographed
on 10-22-24).
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Photo 2. Individual waiting modules
(photographed on 10-22-24).
our inspection, we did not observe overcrowding in any of the clinics’ indoor waiting areas.
Clinic Environment
All clinic environments were sufficiently
conducive for medical care; they provided
reasonable auditory privacy, appropriate waiting
areas, wheelchair accessibility, and
nonexamination room workspace (MIT 5.109,
100%).
Six of the eight applicable clinics we observed
contained appropriate space, configuration,
supplies, and equipment to allow clinicians to
perform proper clinical examinations (MIT 5.110,
75.0%). In two clinics, examination rooms had
unsecured confidential medical records.
Clinic Supplies
Only two of the eight clinics followed adequate
medical supply storage and management
protocols (MIT 5.107, 25.0%). We found one or
more of the following deficiencies in six clinics:
expired medical supplies (see Photo 3, right);
unorganized, unidentified, or inaccurately labeled
medical supplies; cleaning materials stored with
Photo 3. Expired medical supply dated January 31, 2024
(photographed on 10-22-24).
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medical supplies; medications stored
with medical supplies; long-term
storage of staff members’ food in the
medical supply storage area (see Photo
4, left); and staff members’ personal
items and food stored with medical
supplies (see Photo 5, below).
Photo 4. Long-term storage of staff’s food in the medical
supply storage area (photographed on 10-22-24).
Four of the eight clinics met the requirements
for essential core medical equipment and
supplies (MIT 5.108, 50.0%). We found one or Photo 5. Staff’s personal items and food stored
both of the following deficiencies in four with medical supplies (photographed on 10-22-24).
clinics: staff did not always document the
automated external defibrillator (AED)
performance test results within the last 30 days, or the clinic daily glucometer quality control
logs were either inaccurate or incomplete.
We examined emergency medical response bags (EMRBs) to determine whether they
contained all essential items. We checked whether staff inspected the bags daily and
inventoried them monthly. Three of the five EMRBs passed our test (MIT 5.111, 60.0%). In
one location, the EMRB stored a compromised medical supply. In another clinic, staff did not
log EMRB daily glucometer quality control results.
Medical Supply Management
SCC staff performed excellently in storing clinic medical supplies in the medical supply
storage areas outside the clinics (MIT 5.106, 100%).
According to the chief executive officer (CEO), health care leadership did not have any issues
with the medical supply process. Health care and warehouse managers expressed no
concerns about the medical supply chain or their communication process with the existing
system in place.
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Infection Control and Sanitation
Staff appropriately cleaned, sterilized, and disinfected all clinics (MIT 5.101, 100%).
Additionally, staff in all seven applicable clinics properly sterilized or disinfected medical
equipment (MIT 5.102, 100%).
We found operating sinks and hand hygiene supplies in the examination rooms in six of eight
clinics (MIT 5.103, 75.0%). In two clinics, the patient restrooms lacked antiseptic soap and
disposable hand towels.
We observed patient encounters in five clinics. In three clinics, clinicians did not wash their
hands before examining their patients, before applying gloves, before performing blood
draws, or before each subsequent re-gloving (MIT 5.104, 40.0%).
Health care staff in all clinics followed proper protocols to mitigate exposure to bloodborne
pathogens and contaminated waste (MIT 5.105, 100%).
Physical Infrastructure
At the time of our medical inspection, SCC’s administrative team reported no ongoing health
care facility improvement program construction projects. The health care management and
plant operations manager reported all clinical area infrastructures were in good working
order (MIT 5.999).
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Compliance Score Results
Table 10. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately disinfected,
8 0 0 100%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 7 0 1 100%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
6 2 0 75.0%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
2 3 3 40.0%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
8 0 0 100%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 1 0 0 100%
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
2 6 0 25.0%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
4 4 0 50.0%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
8 0 0 100%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
6 2 0 75.0%
providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency crash
carts inspected and inventoried within required time frames, and do they 3 2 3 60.0%
contain essential items? (5.111)
Does the institution’s health care management believe that all clinical areas
This is a nonscored test. Please see the
have physical plant infrastructures that are sufficient to provide adequate
indicator for discussion of this test.
health care services? (5.999)
Overall percentage (MIT 5): 75.0%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical and nursing leadership should determine the root cause(s) for staff not
following all required universal hand hygiene precautions and should
implement remedial measures as appropriate.
• Executive leadership should determine the root cause(s) for staff not following
equipment and medical supply management protocols and should implement
remedial measures as appropriate.
• Nursing leadership should determine the root cause(s) for staff not ensuring
EMRBs are regularly and properly inventoried, stocked, or sealed and should
implement appropriate remedial measures.
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Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions. For
newly arrived patients, our inspectors assessed the quality of health care screenings and the
continuity of provider appointments, specialist referrals, diagnostic tests, and medications.
For patients who transferred out of the institution, inspectors checked whether staff
reviewed patient medical records and determined the patient’s need for medical holds. They
also assessed whether staff transferred patients with their medical equipment and gave
correct medications before patients left. In addition, our inspectors evaluated staff
performance in communicating vital health transfer information, such as preexisting health
conditions, pending appointments, tests, and specialty referrals. Inspectors further
confirmed whether staff sent complete medication transfer packages to receiving
institutions. For patients who returned from off-site hospitals or emergency rooms,
inspectors reviewed whether staff appropriately implemented recommended treatment
plans, administered necessary medications, and scheduled appropriate follow-up
appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Inadequate (74.5%)
Overall, case review found SCC provided poor transfer services. Compared with Cycle 6, we
found more deficiencies overall and more significant deficiencies, the majority of which
occurred when patients returned from a community hospital or emergency room. SCC nurses
and providers frequently did not ensure medication continuity. Additionally, nurses did not
provide complete assessments and appropriate plans of care as their patients’ conditions
warranted. SCC also needed improvement in obtaining hospital records and promptly
scanning records into their patients’ electronic health records. When patients arrived at SCC,
we identified additional opportunities for improvement in nursing documentation. The lack
of documentation impacted our ability to assess the quality of patient care. Additionally,
when patients transferred from SCC, nurses frequently did not assess their patients on the
day of transfer and did not consistently communicate necessary information to the receiving
institution. Considering all factors, the OIG rated the case review component of this indicator
inadequate.
Compliance testing showed SCC had a mixed performance in this indicator. The institution
performed excellently in completing the assessment and disposition sections of the
screening process and ensuring transfer packets for departing patients included all required
documents and medications. In contrast, the institution scored low in completing initial
health screening forms. The institution also needed improvement in medication continuity
for newly transferred patients. Based on the overall Transfers compliance score result, the
OIG rated the compliance testing component of this indicator inadequate.
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Case Review and Compliance Testing Results
OIG clinicians reviewed 48 events in 16 cases in which patients transferred into or out of the
institution or returned from an off-site hospital or emergency room.44 We identified 30
deficiencies, 10 of which were significant.45
Transfers In
SCC showed mixed performance in the transfer-in process. SCC performed excellently in
ensuring providers evaluated patients timely upon arriving to the institution (MIT 1.002,
95.0%). The compliance team also found receiving and release (R&R) nurses always
completed the assessment and disposition section of the screening form (MIT 6.002, 100%).
However, the compliance team found SCC performed poorly in thoroughly completing the
initial health screening form within the required time frame (MIT 6.001, 48.0%). Of the 13
samples tested, five were due to the R&R nurses not thoroughly completing the initial health
screening form. The other eight were due to the Strategic Offender Management System
(SOMS) date and time stamp indicating the nursing staff completed the initial health
screening after the patient transferred to their assigned housing units; under current policy,
the nurse is required to assess patients before they transfer to a housing unit.46 Compliance
testing also found, in two of the four eligible samples, newly arrived patients received
medications one day late (MIT 6.003, 50.0%). Furthermore, when patients arrived for
layover at SCC, compliance testing indicated opportunities for improvement in medication
continuity (MIT 7.006, 75.0%).
OIG clinicians reviewed nine events in five cases for patients who transferred into SCC from
other institutions. We identified six deficiencies, one of which were significant.47 Most
nursing deficiencies related to insufficiently documenting their assessment findings and
patients’ plans of care. Additionally, on two occasions, R&R nurses did not document either
whether the patient arrived with the keep-on-person (KOP) medications or whether they
issued patients their prescribed KOP medications.48 On another occasion, a patient arrived
with a pending specialist referral; the provider extended the compliance date but did not
document the rationale for this decision. Further examples of transfer deficiencies are listed
below:
• In case 18, the patient had a feeding tube and an abdominal incision with 24
staples. The nurses did not ensure feeding tube patency and did not document
the tube length. Furthermore, a nurse documented consulting a provider but did
not document details of this communication, such as wound and feeding tube
44 The events occurred in cases 1, 2, 6, 12-18, and 24-29.
45 Deficiencies occurred in cases 2, 6, 12-15, 17, 18, and 24-29. Significant deficiencies occurred in cases 2, 6, 12, 13, 15, 17, 18,
and 28.
46 The Strategic Offender Management System (SOMS) refers to a comprehensive framework or technology-driven
platform used by law enforcement, correctional services, and criminal justice agencies to manage offenders
throughout their interaction with the criminal justice system. This includes tracking, monitoring, assessing, and
rehabilitating offenders with the goal of improving public safety, reducing recidivism, and ensuring effective use of
resources.
47 Deficiencies occurred in cases 18, 24, 25, and 26. A significant deficiencies occurred in case 18.
48 KOP means “keep-on-person” and refers to medications that a patient can keep and self-administer according to
the directions provided.
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care. Additionally, the nurse did not educate the patient on wound care and
infection prevention measures.
• In case 24, the patient transferred to SCC and was prescribed a rescue inhaler.
The nurse did not assess whether the patient had the rescue inhaler on his
person.
Transfers Out
Our clinician team found opportunities for improvement in SCC’s transfer-out process. OIG
clinicians reviewed six transfer-out events within three cases and identified four deficiencies,
two of which were significant.49 In two of the three cases, nurses did not evaluate their
patients on the day of transfer. Also, for two of the three transferred patients, SCC did not
perform a handoff to ensure continuity of specialist care. Lastly, in one of three cases, nurses
did not administer required medications on the day of transfer and did not notify the
receiving institution or central pharmacy staff the patient had missing essential medications.
The following is an example:
• In case 28, the patient transferred out of SCC. On the day of transfer, the nurse
did not evaluate this patient, did not obtain the patient’s vital signs, and did not
document which specific transfer requirements were met.
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at high risk for
lapses in care quality. These patients typically experienced severe illness or injury. They
require more care and place a strain on the institution’s resources. In addition, because these
patients have complex medical issues, successful health information transfer is necessary for
good quality care. Any transfer lapse can result in serious consequences for these patients.
SCC’s performance varied in the return process for hospitalizations and emergency room
encounters. Compliance testing showed staff usually completed follow-up appointments
within required time frames for patients returning from hospitalizations and emergency
room encounters (MIT 1.007, 92.0%). However, both case review and compliance found
opportunities for improvement in ensuring staff received and scanned hospital records into
the patients’ medical records promptly (MIT 4.003, 75.0%). Compliance testing also found
providers only sometimes reviewed and endorsed documents in a timely manner (MIT
4.005, 52.0%).
Hospital Discharge
OIG clinicians found opportunities for improvement when patients returned from a
community hospital or emergency room. Deficiencies occurred when nurses did not
communicate the hospital provider’s medication recommendations to SCC providers. We
identified additional deficiencies in which providers or nurses initiated incorrect medication
doses and did not timely reconcile medications, resulting in lapses in medication continuity.
On two other occasions, nurses did not issue keep-on-person rescue inhalers. Compliance
testing showed SCC performed poorly in ensuring staff made medication timely available as
well as delivered or administered medications to patients within the required time frames
49 Transfer out deficiencies occurred in cases 27, 28, and 29. Significant deficiencies occurred in case 28.
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(MIT 7.003, 21.1%). Additional information can be found in the Medication Management
indicator.
OIG clinicians reviewed 33 events in 10 cases in which patients returned from off-site
hospitalizations or emergency room encounters. We identified 20 deficiencies, seven of
which were significant.50 The following are examples:
• In case 6, the nurse assessed this patient, who returned from a fire camp, after
an emergency room encounter with a diagnosis of Influenza A (requiring
quarantine). The patient complained of moderately severe throat pain, had an
elevated pulse rate and a moderately low oxygen saturation reading, and
exhibited abnormal lung sounds upon auscultation. The community hospital
emergency room discharge recommendations indicated the patient should take
a full course of an antibiotic for four days and have an albuterol inhaler to use
“at least” four times daily. Though the nurse correctly documented the patient
did not arrive with medications, the nurse did not issue an albuterol inhaler.
Moreover, the nurse incorrectly initiated the order to use the inhaler “as
needed,” instead of directing the patient to use the inhaler four times per day as
recommended.
• In case 15, the nurse assessed the patient after a hospital admission for
congestive heart failure, acute respiratory failure, and atrial flutter.51 During the
hospital admission, the patient was found to have fluid overload and required
diuresis to remove the fluid; however, the nurse did not obtain the patient’s
weight and did not document the rationale for not issuing the newly
recommended rescue inhaler.
Clinician On-Site Inspection
SCC’s R&R department was staffed with an RN on each shift, excluding weekends and
holidays. The R&R nurse indicated an average of 300 patients arrived at SCC and 360
patients departed monthly.
The R&R nurse explained, on Thursdays, custody staff emailed R&R nurses a list of persons
scheduled to transfer from SCC. The R&R nurses would review each patient’s medical record
for pending orders, including orders that would prevent patients from transferring. The
nurse also indicated the R&R nurses tried to assess the patients the day before their
scheduled transfer date to assess vital signs, screen for infectious disease symptoms, and
reconcile prescribed KOP medications and durable medical equipment (DME). The nurse
also indicated sometimes they collected patient’s KOP medications, and other times they
allowed patients to keep medications when doses would be due prior to the transfer. The
nurse shared, when patients were missing medications, the R&R nurses would inform the
receiving institution by email, and the patients were instructed to submit a sick call request
to obtain their missing medications at the new institution. Additionally, the nurse indicated
they would consult with a provider when a patient’s essential medications were missing.
50 Patients returned from a hospitalization or emergency room encounters occurred in cases 1, 2, 6, 12-18.
Deficiencies occurred in cases 2, 6, 12-15, 17, and 18. A significant deficiency occurred in cases 2, 6, 12, 13, 15, and
17.
51 Atrial flutter is a type of abnormal heart rhythm where the heart beats too fast. This fast heart rhythm can lead to
symptoms of palpitations, fatigue or dizziness.
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The CNE indicated, when patients transferred out from SCC, R&R nurses were only expected
to review the patients’ active orders; the nurses were not expected to perform a chart review.
The CNE also indicated the nursing supervisors were not expected to formally evaluate the
R&R nurses’ performance. Instead, they performed random R&R audits; however, SCC could
not provide documentation of these audits. The CNE explained she did not review the
context of this information and indicated she planned to implement a formal audit to assess
nursing quality for the transfer-out process.
Compliance On-Site Inspection and Discussion
R&R nursing staff ensured all seven applicable patients transferring out of the institution had
their required medications, transfer documents, and assigned DME (MIT 6.101, 100%).
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Compliance Score Results
Table 11. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Did nursing
staff complete the initial health screening and answer all screening 12 13 0 48.0%
questions within the required time frame? (6.001)
For endorsed patients received from another CDCR institution: When
required, did the RN complete the assessment and disposition section of
the initial health screening form; refer the patient to the TTA if TB signs and 17 0 8 100%
symptoms were present; and sign and date the form on the same day staff
completed the health screening? (6.002)
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 2 2 21 50.0%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer packet 7 0 3 100%
required documents? (6.101)
Overall percentage (MIT 6): 74.5%
Source: The Office of the Inspector General medical inspection results.
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Table 12. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 19 1 5 95.0%
patient seen by the clinician within the required time frame? (1.002)
Upon the patient’s discharge from the community hospital: Did the patient
receive a follow-up appointment with a primary care provider within the 23 2 0 92.0%
required time frame? (1.007)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 15 5 5 75.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 13 12 0 52.0%
review the report within five calendar days of discharge? (4.005)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient 4 15 6 21.1%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
25 0 0 100%
medications continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 3 1 0 75.0%
administered or delivered without interruption? (7.006)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
8 5 0 61.5%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should develop and implement strategies, such as internal
staff auditing, to ensure assessments are complete and thorough for patients
who transfer in, transfer out, or return from the hospital or emergency room.
• Medical and nursing leadership should develop and implement a process
between nursing and providers to ensure they promptly review all hospital
discharge recommendations and timely place orders.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in administering
prescription medications on time and without interruption. The inspectors examined this
process from the time a provider prescribed medication until the nurse administered the
medication to the patient. In addition to examining medication administration, our
compliance inspectors also tested many other processes, including medication handling,
storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (59.9%)
In this cycle, case review found SCC usually provided sufficient medication management to
the patients housed at SCC; however, the clinicians’ case review samples did not include
patients assigned to fire camp areas. Consequently, the case review results were entirely
determined from patients housed at SCC. Although the case review process occasionally
identified opportunities for improvement in chronic care medication continuity, the OIG
clinicians found nurses performed well with issuing and administering prescribed
medications to patients. Compared with Cycle 6, we identified fewer overall deficiencies.
Considering all factors, the OIG rated the case review component of this indicator adequate.
Compliance testing showed SCC needed improvement in providing medication management
services. SCC performed poorly in providing patients with chronic care medications, newly
ordered medications, transfer-in medications, and community hospital discharge
medications. Compliance testing also identified opportunities for improvement in ensuring
medication continuity for patients laying over at SCC. Based on the overall Medication
Management compliance score result, the OIG rated the compliance testing component of
this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 112 events in 26 cases related to medications and found 19 medication
deficiencies, seven of which were significant.52
New Medication Prescriptions
Compliance testing revealed newly prescribed medications were either not available or not
timely administered (MIT 7.002, 44.0%). In contrast, case review found only two cases in
which newly prescribed medications were not issued or administered to patients as ordered.
An example is detailed below:
52 Deficiencies occurred in cases 8, 11-15, 17, 18, and 23. Significant deficiencies occurred in cases 8, 11, 12, 13, and
15.
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• In case 8, the patient was to begin new dosages of two medications for diabetes;
however, the patient never received those medications as ordered, and the
medication dosage was adjusted again a few weeks later.
Chronic Medication Continuity
Compliance testing revealed medications were only occasionally available and issued to
patients within the required time frames (MIT 7.001, 18.8%). OIG clinicians found four cases
in which patients did not timely receive chronic care medications or did not receive them at
all.53 An example is listed below.
• In case 11, medication continuity was interrupted when the patient did not
receive a one-month supply of chronic care blood pressure medication in the
month of April.
Hospital Discharge Medications
OIG clinicians found opportunities for improvement in medication continuity when patients
returned from a community hospital or emergency room. Please refer to the Transfers
indicator for additional details.
Compliance testing showed SCC performed poorly in ensuring staff administered, made
available, and delivered medications to patients within the required time frames (MIT 7.003,
21.1%).
Transfer Medications
Compliance testing showed SCC performed excellently in ensuring patients who transferred
from yard to yard received their medications timely (MIT 7.005, 100%), and patients leaving
the institution had appropriate medications in their transfer envelopes (MIT 6.101, 100%).
In contrast, case review found opportunities for improvement when receiving and release
(R&R) nurses did not administer essential medications before a patient’s transfer and did
not inform the receiving institution or pharmacy of the patient’s missing medications.
Compliance testing showed patients at SCC on layover inconsistently received their
medications (MIT 7.006, 75.0%). Furthermore, compliance tests found staff maintained
medication continuity for only half of newly arrived patients (MIT 6.003, 50.0%). Similarly,
OIG clinicians found, when patients had an existing order for a rescue inhaler, the R&R nurse
did not confirm whether the patients had their inhalers on their person and did not issue the
patients new inhalers.
Additional information can be found in the Transfers indicator.
Medication Administration
Compliance testing showed nurses performed excellently in administering tuberculosis (TB)
medications within required time frames (MIT 9.001, 100%). OIG clinicians did not have any
53 Patients received untimely chronic care medications in cases 8, 11, 13, and 15.
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case review samples with events related to TB medications. OIG clinicians found nurses
performed well overall in administering prescribed medications.
Clinician On-Site Inspection
During the on-site inspection, OIG clinicians met with the pharmacist in charge (PIC) and
discussed both specific patients and pharmacy operations, including medication distribution
to the 31 fire camps throughout California. The PIC explained the SCC pharmacy along with
the A yard nursing staff were responsible for camp medication distribution. The PIC
indicated most of the fire camp patients’ medications were filled through CCHCS’s central fill
pharmacy and delivered to the SCC pharmacy, which accepted the medications. The
pharmacy staff then delivered the camp patients’ medications to the A facility nurse. This
nurse made a copy of the medication administration record (MAR) to later reconcile when
the patients received their medications. Once per week, an internal transportation courier
obtained the medications and the corresponding MAR, and delivered them to the patients’
assigned camps. Custody staff at the fire camps issued the patients their medications and
instructed the patients to sign the MAR. Custody staff was then responsible to fax the signed
MAR to the A facility medication area, where the LVN could then reconcile the signed MAR
and document the medication was administered on the MAR in EHRS.54 Staff later scanned
the MAR into the patient’s medical record.
In the event the patient was not at the fire camp and was deployed to an active fire, the
medications were returned to the SCC pharmacy utilizing the transportation courier system.
The PIC explained the pharmacy staff did not inform the A facility nurse of the returned
medications, which the A yard nurse confirmed during interview. The LVN indicated, when
they did not receive a signed MAR, the nurses continued to contact the fire camp’s custody
staff by telephone until they received a signed MAR. The clinicians also learned pharmacy
staff did not attempt to reissue these returned medications. Instead, actively deployed
patients were required to utilize the sick call process to request a medication refill. However,
when camp patients returned to the fire camp from the emergency room or urgent care and
required medications urgently, SCC had a system in place allowing pharmacists located near
the fire camps to fill the prescriptions.
OIG clinicians also went to the C facility medication administration area, which was located
in the medical clinic. The medication administration area was staffed with two LVNs during
the morning shift and three LVNs during the afternoon shift. An LVN informed the clinicians
how they distributed work: one LVN completed the daily diabetic line and the weekly
“Ozempic” line, while the other LVN would administer and issue KOP medications. The nurse
indicated pharmacy staff delivered medications two to three times each business day. The
nurses prepared a KOP pick-up list, which they posted in the medication administration
window, in the dining hall, and in the housing units. The LVN explained patients could pick
up their KOP medication at any time during the morning and afternoon shifts. If the patients
did not pick up or refused their KOP medications, the LVN would educate the patient at the
window or refer the patient to the LVN care coordinator for further education.
54 EHRS is the Electronic Health Records System. The department’s electronic health record system is used for
storing the patient’s medical history. The health care staff use the system to communicate. This record stays with the
patient throughout the patient’s time in department’s correctional system.
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Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in all of eight applicable
clinic and medication line locations (MIT 7.101, 100%).
SCC appropriately stored and secured nonnarcotic medications in only three of eight
applicable clinic and medication line locations (MIT 7.102, 37.5%). In five locations, we
observed one or more of the following deficiencies: nurses did not maintain unissued
medication in its original labeled packaging; the medication storage area was disorganized;
the treatment cart log was missing daily security check entries; and the medication nurse did
not follow the process in place to return medications with an expired pharmacy label that
can be potentially restocked and reissued by the pharmacy.
Staff kept medications protected from physical, chemical, and temperature contamination in
six of the eight applicable clinic and medication line locations (MIT 7.103, 75.0%). In one
location, staff stored medication with cleaning materials, and the medication refrigerator
was unsanitary. In the other location, staff did not separate the storage of oral and topical
medications.
Staff successfully stored valid, unexpired medications in six of the eight applicable
medication line locations (MIT 7.104, 75.0%). In two locations, we found expired
medications.
Nurses exercised proper hand hygiene and contamination control protocols in only two of
seven applicable locations (MIT 7.105, 28.6%). In the remaining five locations, nurses
neglected to wash or sanitize their hands when required, such as before applying gloves or
before each subsequent re-gloving.
Staff in all medication preparation and administration areas showed appropriate
administrative controls and protocols when preparing medications for patients (MIT 7.106,
100%).
Staff in three of seven applicable medication areas used appropriate administrative controls
and protocols when distributing medications to their patients (MIT 7.107, 42.9%). In three
clinics, we observed a medication nurse who did not follow the CCHCS care guide when
administering Suboxone medication. In the remaining clinic, medication nurses did not
reliably observe patients while they swallowed direct observation therapy medications, and
we observed medication nurses who did not properly disinfect the vial’s port prior to
withdrawing medication.
Pharmacy Protocols
SCC followed general security, organization, and cleanliness management protocols in its
pharmacy (MIT 7.108, 100%).
In its pharmacy, staff did not properly store nonrefrigerated medication (MIT 7.109, zero).
We found the following deficiencies: unorganized medications, an inaccurately labeled
medication storage bin, and bulk food stored long-term within the medication area.
The institution did not properly store refrigerated or frozen medications in its pharmacy
(MIT 7.110, zero). We found an unsanitary medication refrigerator.
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The PIC correctly accounted for narcotic medications stored in SCC’s pharmacy (MIT 7.111,
100%).
We examined nine medication error reports. The PIC timely and correctly processed all
reports (MIT 7.112, 100%).
Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors
followed up on any significant medication errors found during compliance testing. We did
not score this test; we provide these results for informational purposes only. At SCC, the OIG
did not find any applicable medication errors (MIT 7.998).
The OIG interviewed patients in restricted housing unit to determine whether they had
immediate access to their prescribed asthma rescue inhalers or nitroglycerin medications.
All 10 applicable patients we interviewed indicated they had access to their rescue
medications (MIT 7.999).
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Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
3 13 9 18.8%
or did the institution follow departmental policy for refusals or no‑shows? (7.001)
Did health care staff administer, make available, or deliver new order prescription
11 14 0 44.0%
medications to the patient within the required time frames? (7.002)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 4 15 6 21.1%
required time frames? (7.003)
For patients received from a county jail: Were all medications ordered by the
institution’s reception center provider administered, made available, or delivered to N/A N/A N/A N/A
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
25 0 0 100%
continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily housed patient
had an existing medication order, were medications administered or delivered 3 1 0 75.0%
without interruption? (7.006)
All clinical and medication line storage areas for narcotic medications: Does the
institution employ strong medication security controls over narcotic medications 8 0 3 100%
assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution properly secure and store nonnarcotic medications in the assigned 3 5 3 37.5%
storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution keep nonnarcotic medication storage locations free of contamination in 6 2 3 75.0%
the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution safely store nonnarcotic medications that have yet to expire in the 6 2 3 75.0%
assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ and follow
hand hygiene contamination control protocols during medication preparation and 2 5 4 28.6%
medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 7 0 4 100%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 3 4 4 42.9%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization, and
1 0 0 100%
cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
0 1 0 0
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
0 1 0 0
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
1 0 0 100%
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting protocols?
9 0 0 100%
(7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the OIG This is a nonscored test. Please see the indicator
find that medication errors were properly identified and reported by the institution?
(7.998) for discussion of this test.
Pharmacy: For Information Purposes Only: Do patients in restricted housing units This is a nonscored test. Please see the indicator
have immediate access to their KOP prescribed rescue inhalers and nitroglycerin
medications? (7.999) for discussion of this test.
Overall percentage (MIT 7): 59.9%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 2 2 21 50.0%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer-packet 7 0 3 100%
required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
25 0 0 100%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 24 1 0 96.0%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient N/A N/A N/A N/A
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• SCC leadership should develop and implement measures to ensure the fire camp
patients receive all medications without delay and ensure pharmacy staff
communicate with nurses when medications are returned to the institution.
Leadership should implement remedial measures as appropriate.
• SCC leadership should determine the challenges to providing medication
continuity for patients with chronic care medications, newly ordered
medications, transfer-in medications, and community hospital discharge
medications. Leadership should implement remedial measures as appropriate.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
patients out quickly. The OIG rated this indicator solely according to the compliance score.
Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Adequate (84.7%)
SCC performed well overall in this indicator. Staff performed excellently in administering TB
medications to patients as prescribed, monitoring patients taking TB medications, offering
patients an influenza vaccine for the most recent influenza season, and offering colorectal
cancer screening for patients from ages 45 through 75. However, staff needed improvement
in screening patients annually for TB. In addition, they performed poorly in offering required
immunizations to chronic care patients. These findings are set forth in the table on the next
page. Based on the overall Preventive Services compliance score result, the OIG rated this
indicator adequate.
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Compliance Score Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
25 0 0 100%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 24 1 0 96.0%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
17 8 0 68.0%
(9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
25 0 0 100%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients? (9.008) 4 5 16 44.4%
Are patients at the highest risk of coccidioidomycosis (Valley Fever)
N/A N/A N/A N/A
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 84.7%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Health care leadership should determine the root cause(s) for challenges to
timely providing immunizations to chronic care patients and should implement
appropriate remedial measures.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care delivered by the institution’s
nurses, including registered nurses (RN), licensed vocational nurses (LVN), psychiatric
technicians (PT), certified nursing assistants (CNA), and medical assistants (MA). Our
clinicians evaluated nurses’ performance in making timely and appropriate assessments and
interventions. We also evaluated the institution’s nurses’ documentation for accuracy and
thoroughness. Clinicians reviewed nursing performance across many clinical settings and
processes, including sick call, outpatient care, care coordination and management,
emergency services, specialized medical housing, hospitalizations, transfers, specialty
services, and medication management. The OIG assessed nursing care through case review
only and performed no compliance testing for this indicator.
When summarizing nursing performance, our clinicians understand nurses perform
numerous aspects of medical care. As such, specific nursing quality issues are discussed in
other indicators, such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
In Cycle 7, case review found SCC’s nursing performance declined. Compared with Cycle 6,
SCC nurses’ overall deficiencies and significant deficiencies both increased. OIG clinicians
found medication management was a relative strength, as most nurses administered
medication as prescribed. However, OIG clinicians also identified reoccurring patterns in
outpatient assessments, emergency care, documentation, and care coordination. Common
deficiencies included incomplete nursing assessments, delayed or absent provider
consultations, and inadequate documentation of patient symptoms and clinical findings. We
cited specific concerns regarding missing same-day evaluations of urgent sick call
complaints, poor wound care documentation, and gaps in continuity of care when patients
returned from a community hospital or emergency room, transferred into or out of SCC, or
returned from an off-site specialist appointment. These findings reflect systemic challenges
in clinical decision making, communication, and comprehensive documentation that may
compromise patient safety and care quality. In addition, SCC’s nursing leadership did not
identify opportunities for improvement and did not have sufficient mechanisms in place to
monitor the quality of nurses’ clinical performances. The OIG rated the case review
component of this indicator inadequate.
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Case Review Results
We reviewed 158 nursing encounters in 38 cases. Of the nursing encounters we reviewed, 67
were in the outpatient setting, and 50 were sick call requests. We identified 90 nursing
performance deficiencies, 21 of which were significant.55
Outpatient Nursing Assessment and Interventions
A critical component of nursing care is the quality of nursing assessment, which includes
both subjective (patient interviews) and objective (observation and examination) elements.
Nurses needed improvement in their assessments, interventions, and plans of care. OIG
clinicians identified 41 outpatient nursing deficiencies, eight of which were significant.56
These deficiencies occurred when nurses performed sick call triage and did not arrange a
next business day appointment when the patient had symptoms. The nurses also did not
arrange a same day appointment when the patient’s symptoms warranted. Additionally,
nurses’ assessments were frequently incomplete, and nurses inconsistently consulted a
provider when their patients condition warranted. Examples are listed in the following cases:
• In cases 6, 15, 32, 35, 39, 40, and 41, nurses assessed these patients but did not
obtain complete vital signs.
• In case 11, the nurse reviewed a sick call complaint for chest and back pains.
Considering the patient’s medical history, high risk medical status, and
complaints, the nurse should have assessed the patient the same day but instead
arranged an appointment for the next day.
• In case 15, on a Sunday, a nurse had concerns when a heart failure patient in the
housing unit had increased shortness of breath and was unable to ambulate to
the medication line due to difficulty breathing. The nurse also documented
concerns the patient had fluid overload.57 However, instead of promptly
consulting a provider, the nurse sent a message in the EHRS to the provider and
care team. Additionally, the nurse did not obtain the patient’s vital signs or listen
to lung sounds and did not subjectively assess the patient’s KOP medication
compliance.
• In case 18, the nurse triaged the sick call request in which this patient reported
diarrhea, fatigue, and vomiting blood. The nurse did not initiate a nursing
appointment during the review period for these sick call complaints. We
identified similar deficiencies in cases 10, 11, and 14.
Outpatient Nursing Documentation
Complete and accurate nursing documentation is an essential component of patient care.
Without proper documentation, health care staff can overlook changes in patients’
55 Deficiencies occurred in cases 1-4, 6, 10-15, 17, 18, 21, 24-37, and 39-41. Significant deficiencies occurred in
cases 2-4, 6, 11, 13, 15, 18, 21, 28, 35, and 37.
56 Deficiencies occurred in cases 1, 2, 6, 10-15, 18, 21, 30-37, 39, 40, and 41. Significant deficiencies occurred in
cases 2, 11, 15, 18, 35, and 37.
57 Fluid overload occurs when there is excess fluid in the body, which may lead to swelling, high blood pressure, or
other medical complications.
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conditions. Nurses sometimes documented care thoroughly; however, examples of
opportunities for improvement are listed below:
• In case 34, a sick call nurse assessed a patient with a back rash. The nurse did
not document the rash appearance.
• In case 39, the nurse assessed the patient for arm numbness, but the nurse did
not document whether the numbness was in the right or left arm.
Wound Care
We reviewed four cases in which patients had wounds and required wound care.58 We
identified opportunities for improvement in each of these cases. In all four cases, nurses did
not provide thorough descriptions of the wounds. In two cases, the nurses did not consult a
provider when warranted. An example of poor nursing assessment and documentation is
listed below:
• In case 18, an RN assessed this patient who had an abdominal incision and a
gastric tube.59 The gastric tube stoma was red and had drainage. The nurse did
not assess when the redness and drainage began and did not document the
amount of drainage.
Emergency Services
We reviewed 40 urgent or emergent events, we identified 24 nursing deficiencies, six of
which were significant.60 Nurses responded promptly to emergent events. We identified a
pattern in which nurses did not intervene sufficiently in emergencies, which we detail
further in the Emergency Services indicator. The following are examples:
• In case 6, an LVN requested a TTA RN when the patient had difficulty breathing;
however, the LVN did not obtain the patient’s respiratory rate, oxygen saturation
level, or any other vital signs.
• Also in case 6, when the TTA RN arrived, the patient’s oxygen saturation result
was significantly low, breathing was irregular, and the patient had an elevated
pulse. The RN initiated oxygen; however, the RN did not increase the rate of
oxygen administration to maintain an adequate oxygen saturation level.
Additionally, the RN did not place the patient in a position to promote
oxygenation and did not sufficiently monitor the patient’s vital signs.
Hospital Returns
We reviewed 18 nursing events in nine cases that involved returns from off-site hospitals or
emergency rooms. We identified 10 nursing deficiencies, three of which were significant.61
58 Wound care occurred in cases 14, 17, 18, and 21.
59 A gastric tube, often called a G-tube, is a soft, flexible tube inserted into the stomach, which is used deliver food,
fluids, and medication to someone who cannot swallow or eat safely by mouth.
60 Nursing deficiencies occurred in cases 2-4, 6, 11-13, 15, and 17. Significant deficiencies occurred in cases 2-4, 6,
13, and 15.
61Deficiencies occurred in cases 6, 12-15, 17, and 18. Significant deficiencies occurred in cases 6, 13, and 15.
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Nurses performed poorly in providing thorough assessments and interventions, which we
detailed further in the Transfers indicator. The following are examples:
• In case 12, this patient returned to SCC after a hospital admission for rectal
bleeding, anemia, and ulcerative colitis. The patient had abdominal pain;
however, the nurse did not describe the patient’s abdominal appearance and did
not palpate the abdomen for tenderness.
• In case 13, this patient with a history of a stroke returned to SCC after a
community emergency room encounter. The emergency room provider
indicated the patient should have been taking a daily blood thinner; however,
the patient’s order for the blood thinner had expired nine days prior. The nurse
did not consult the provider to obtain an order for this essential medication.
Transfers
We reviewed eight cases involving transfer-in and transfer-out processes and identified
seven nursing performance deficiencies, two of which were significant and are detailed
further in the Transfers indicator. The following is an example:
• In case 29, the patient transferred from SCC. The nurse did not communicate to
the receiving facility the patient’s pending endocrinology referral. Also, on the
day of transfer, the nurse did not document assessing the patient.
Specialty Services
We reviewed 23 events within seven cases in which patients returned after specialty
procedures or consultations. We identified seven deficiencies, two of which were
significant.62 OIG clinicians found opportunities for improvement when nurses either did not
initiate provider follow-ups at all or did not initiate a provider follow-up within the required
time frame. Please refer to the Specialty Services indicator for additional details.
Medication Management
OIG clinicians reviewed 112 events involving medication management and found most
nurses administered patients’ medications as prescribed. Please refer to the Medication
Management indicator for additional details.
Clinician On-Site Inspection
During the on-site inspection, the OIG clinicians met with nursing staff, supervisors, and the
CNE. While touring the various medical areas, we interviewed nurses and medical staff. OIG
clinicians inquired about various systems in place to ensure patient care continuity.
OIG clinicians attended huddles in both A/B yard and C yard medical clinics. The medical
assistants (MAs) conducted the shared huddle in the A/B yard medical clinic, while an LVN
care coordinator and an MA conducted the C yard medical clinic huddle. Both clinics’
presenters utilized the pre-populated standardized huddle reports and did not present
patient specific information. Instead, they only reported the number of patients for each
62 Deficiencies occurred in cases 12, 13, 15, 18, and 21. Significant deficiencies occurred in cases 13 and 21.
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topic of the huddle. These huddles were conducted rapidly and the sections with patients
warranting possible action or discussion were not addressed. The TTA nursing staff reported
discussing patients returning from a routine specialty service appointment at the morning
huddles to determine whether a follow-up was clinically necessary. However, the OIG
clinicians observed the care teams did not discuss whether patients returning from specialty
appointments needed follow-up appointments in any of the huddles. After the A/B yard
medical clinic huddle, the OIG clinicians inquired about a few of the patients listed on the
huddle report whose cases warranted clarity or who may have required a care team follow-
up. After discussion with the care team, OIG clinicians found the care team was not
knowledgeable regarding their patient population, despite reviewing the EHRS. Please refer
to the Access to Care indicator for further details.
OIG clinicians learned the C facility housed medium- and high-risk patients, including those
requiring mental health services and those in restrictive housing units. In the A/B facility, the
population consisted of patients who hoped to attend a fire camp. The clinicians interviewed
a supervising registered nurse (SRN). The SRN reported conducting monthly RN sick call
audits, which consisted of auditing five patients who the sick call RN had scheduled and
assessed. The SRN indicated the audit was only conducted for the one primary care RN;
therefore, the audit did not include all RNs performing sick calls. During OIG clinicians’
inspection, the clinicians interviewed an LVN care coordinator who had been in this position
for the past two years. The LVN shared she had received no formal training for the role,
relying instead on peer learning and self-initiated processes.
SCC medical staff and leadership shared information about their fire camps. The clinicians
learned a large percent of SCC patients resided in 31 fire camps throughout California,
including incarcerated persons who were trained in firefighting skills or other needed
functions at the camp, such as cooks and grounds maintenance workers. Although a majority
of this population were considered “healthy,” SCC medical leadership indicated these patients
could access health care and request medication refills utilizing the sick call process. OIG
clinicians asked various medical staff specific details about how SCC RNs received patients’
sick call requests; however, the responses were inconsistent. Some staff indicated the camp
custody staff collected the requests, which they picked up weekly and transported by vehicle
to SCC. Once at the institution, these staff indicated the camp custody staff would drop off the
requests to the SCC mail room or the SRN office or a medical clinic. Other staff, however,
stated camp custody sometimes faxed or emailed requests to the TTA nurses or to the A yard
LVNs managed medication refills. OIG clinicians also inquired whether the public health
nurse (PHN) was involved in addressing ongoing public health or communicable disease
concerns that occurred within the fire camps. The PHN and infection control nurse both
reported they were not involved with the fire camps, other than ensuring patients’
immunizations met the fire camp.
OIG clinicians also learned about SCC’s medical emergency response team (MERT). This
team was led by an SRN, who ensured medical supplies and staff were always prepared to
deploy. SCC’s MERT team was composed of a medical provider and nursing staff members
who traveled to the staging area of wildfires to care for both incarcerated and community fire
fighters. When this occurred, SCC’s medical and nursing staff who remained at the institution
would cover the vacated positions.
OIG clinicians met with the CNE and discussed specific patient questions as well as SCC’s
missions and operations. The CNE, who had been in this role at SCC for two years, indicated
SCC did not currently have a formal process to evaluate the quality of nursing care. In
addition, SCC did not have a process to proactively identify areas of improvement other than
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its emergency medical response (EMR) clinical review process when patients had an
unscheduled transfer to a higher level of care. After researching patient-specific questions
the OIG clinicians presented, the CNE acknowledged SCC nursing areas needed
improvements. The CNE hoped CCHCS’s quality management team would assist SCC in
developing processes to monitor and improve nursing performance.
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Recommendations
• Nursing leadership should identify the challenges preventing SCC nurses from
performing complete assessments and interventions and should implement
remedial measures as appropriate.
• Nursing leadership should develop and implement strategies, such as sick call
audits, to ensure supervisors evaluate the nursing triage process to confirm the
nurses properly assess patients’ requests and schedule patients with urgent or
emergent symptoms in an appropriate time frame. Leadership should
implement remedial measures as appropriate.
• SCC nursing and medical leadership should develop strategies to ensure
primary care huddles are thorough and comprehensive, and the care teams
address all pending or unresolved items. Leadership should implement
remedial measures as appropriate and educate all medical staff on proper
huddle expectations.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of care delivered by the
institution’s providers: physicians, physician assistants, and nurse practitioners. Our
clinicians assessed the institution’s providers’ performance in evaluating, diagnosing, and
managing their patients properly. We examined provider performance across several clinical
settings and programs, including sick call, emergency services, outpatient care, chronic care,
specialty services, intake, transfers, hospitalizations, and specialized medical housing. We
assessed provider care through case review only and performed no compliance testing for
this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
Case review found SCC providers delivered overall poor care, declining significantly since
Cycle 6. During Cycle 7, the number of provider deficiencies doubled and the number of
significant deficiencies increased from two to 35. Nine of the 20 cases we reviewed were
inadequate in Cycle 7 versus only two in Cycle 6. Deficiencies and errors increased as the
patients were more medically complex or had unusual presentations. We found poor
provider assessment, decision making, and lapses in medical chart review in multiple cases.
In addition, providers periodically ordered specialty service referrals with priority time
frames that were not appropriate for the patients’ medical conditions. While documentation
was generally complete, we found missing progress notes for important events. Providers
usually sent patient test notification letters, but the letters did not always contain all
required components. On a positive note, providers usually timely endorsed diagnostic
reports, off-site specialty reports, hospital reports, and laboratory reports. After careful
consideration of all factors, the OIG rated this indicator inadequate.
Case Review Results
OIG clinicians reviewed 119 medical provider encounters and identified 111 deficiencies, 35
of which were significant.63 In addition, we examined the quality of care in 20 comprehensive
case reviews. Of these 20 cases, we found 11 adequate and nine inadequate, primarily due to
poor provider performance.
Outpatient Assessment and Decision-Making
Providers’ performance with appropriate assessments and decision making varied. OIG
clinicians identified 49 outpatient provider assessment and decision-making deficiencies, 20
of which were significant.64 Poor decision making related more to the degree of patient
medical complexity than to any particular provider, although some providers had more
63 Deficiencies occurred in cases 1-2, 6-23, 26, and 28. Significant deficiencies occurred in cases 2, 6, 8, 11-13, 15,
17-18, 20-21, and 23.
64 Deficiencies occurred in cases 2, 6-9, and 11-23. Significant deficiencies occurred in cases 2, 6, 8, 11-13, 15, 17,
18, 20-21, and 23.
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deficiencies than others. We found deficiencies with not addressing abnormal vital signs, not
ordering follow-up appointments or not ordering them timely, poor physical exams, errors in
diagnoses, and allowing critical medications to expire. The following are examples of
significant deficiencies:
• In case 2, the provider erroneously documented the patient had a history of
atrial fibrillation, both in the patient’s medical record and with a recent
echocardiogram.65 However, the medical record actually contained no prior
objective evidence or medical history of atrial fibrillation. The echocardiogram
also showed no atrial fibrillation. Based on this error, the provider ordered a
cardiology specialty follow-up to determine whether the patient needed
cardioversion or anticoagulation medication. Both of these carry significant
medical risks. This error and inaccurate diagnosis would have not only caused
the patient distress but may have subjected him to unnecessary treatments and
procedures.
• Also in case 2, two months later the provider evaluated the patient for hospital
follow-up for chest pain, thrombolytic therapy, and cardiac catheterization.66 In
this post-hospital evaluation, the provider documented not having received
hospital documentation but noted the patient mentioned having 55 percent
coronary blockage. Despite not having the hospital documentation, the provider
added coronary artery disease (CAD) to this patient’s medical problem list
without confirmation and without knowing the patient had misunderstood his
hospital diagnosis. Three days later, the provider reviewed and endorsed the
associated hospital reports, which clearly documented the patient did not have
significant coronary artery disease by cardiac catheterization. However, the
provider did not recognize the discrepancy, did not clarify the error to the
patient, and did not correct the diagnosis or problem in the patient’s chart. The
provider continued her misdiagnoses of atrial fibrillation and coronary artery
disease in this relatively healthy patient throughout the review period. The
patient paroled to the community believing he had two significant cardiac
conditions that he, in fact, did not have.
• In case 12, the patient underwent a colonoscopy, which confirmed a significant
diagnosis of colitis and proctitis, and the specialist recommended starting the
patient on important medications.67 Upon the patient’s return to SCC, the on-call
provider ordered the recommended medications and provider follow-up
appointment to occur in 14 days. On the appointment day, the provider did not
see the patient but reviewed the colonoscopy report, documented an out-to-
medical return progress note, and closed the appointment as completed despite
not having seen the patient. Due to the significance of the colonoscopy findings
and the importance of medication compliance, the provider should have seen
the patient and should not have marked the appointment as completed when
the patient was not seen. Ten days later, the patient was transferred to the
hospital for rectal bleeding and severe anemia due to colitis, which may have
65 An echocardiogram is a procedure using an ultrasound to examine and image the heart.
66 Thrombolytic therapy is the use of medications to dissolve blood clots inside blood vessels to restore blood flow.
Cardiac catheterization is a medical procedure used to diagnose and treat heart blood vessel blockages.
67 Colitis is irritation or swelling of the lining of the colon. Proctitis is irritation or swelling of the lining of the
rectum.
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been prevented had the provider seen the patient and discussed the treatment
plan.
• Also in case 12, one month after the above hospitalization, the provider allowed
this patient’s only ulcerative colitis medication to expire. The medication is used
to control the inflammation, helping to reduce bleeding. This medication lapse
contributed to a four-day hospitalization another month later for a significant
rectal ulcerative colitis flair and severe anemia, requiring blood transfusions.
The patient’s suffering and the hospitalization may have been preventable had
the provider ensured the continuity of this patient’s medication.
• In case 17, the provider evaluated this patient with a history of removal of a
portion of the small intestines for blockage and intussusception.68 The patient’s
blood pressure was critically low and oxygen saturation abnormal; however, the
provider did not address either of these abnormal vital signs. Two weeks later,
the patient was hospitalized in the ICU for heart failure, sepsis, and other
conditions. Again, this may have been prevented had the provider taken steps to
further address the abnormal vital signs at the appointment two weeks prior.
Review of Records
Providers frequently reviewed records appropriately; however, we found nine errors, one of
which was significant.69 Most of these errors involved provider review of current treatment
plans and pertinent medical histories. Inappropriate record review can lead to medical
errors, as follows:
• In case 11, the patient’s diabetes was not well controlled. On two separate
occasions, the provider did not thoroughly review the patient’s medication
administration record and, as a result, inaccurately documented the patient’s
uncontrolled diabetes was due to frequent medication refusals when the patient
was actually medication compliant. The provider also did not adjust an
important diabetes medication that would have improved the patient’s diabetes.
• In case 21, the provider evaluated the patient to follow up on a recurrent neck
abscess.70 The patient had developed new lesions while taking the antibiotic,
clindamycin, indicating the medication was not effective. However, the provider
did not adequately review the record, so the provider was unaware the patient
had completed the antibiotic course three days prior. The provider also did not
acknowledge the antibiotic was not helping. As a result, the provider simply
ordered the patient to complete the clindamycin course instead of starting a
more effective antibiotic or culturing the draining wounds. Fourteen days later,
the patient was transferred to the hospital for worsening infection, which may
have been preventable.
68 Intussusception is a medical emergency in which a portion of the intestine slides over another portion, creating a
telescoping effect.
69 Deficiencies occurred in cases 2, 11, 15, 18, 21, and 22. A significant deficiency occurred in case 21.
70 An abscess is a localized collection of pus, usually caused by a bacterial infection.
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Emergency Care
Providers performed poorly in provider emergency care. OIG clinicians reviewed 40
emergency events and identified 21 deficiencies, seven of which were significant. Thirteen of
the 21 deficiencies related to poor provider assessment and decision making, five of which
were significant.71 In addition, providers did not always complete documentation. We
discussed this further in the Emergency Services indicator.
Chronic Care
Providers performed sufficiently in managing stable, noncomplex patients who had typical
presentations of common chronic medical conditions, such as hypertension, diabetes, and
asthma. Providers needed improvement in appropriately managing patients with unusual
presentations or multiple medical problems. OIG clinicians reviewed 24 provider events
involving chronic care and identified 16 deficiencies, four of which were significant as
follows:72
• In case 12, the patient with chronic parathyroid disorder and colitis had rectal
bleeding and, eventually, inflammation and bleeding of the colon that required
medication and close monitoring.73 When the patient’s blood counts dropped,
indicating the patient continued to bleed, the provider did not see the patient
but instead ordered a blood test to be completed in two weeks. The patient was
hospitalized three days later, at which time the patient required blood
transfusions.
• Also in case 12, after this hospitalization, the patient submitted a sick call slip
for symptoms of heavy bleeding from the rectum, and being thirsty, weak, and
pale. The RN scheduled an appointment, but the patient refused. Additionally, an
important medication for his colitis had expired. A few days later, the provider
evaluated the patient but only addressed the patient’s POLST.74 The provider did
not address the patient’s expired medication and did not address the patient’s
complaints of worsening symptoms. The patient’s condition continued to
worsen, and about two weeks later, the patient was hospitalized again.
• In case 15, the patient suffered from congestive heart failure and his health
continued to worsen. On at least two separate occasions, the providers did not
perform appropriate physical examinations or widen the differential diagnosis
to include other conditions that could be causing the patient’s deterioration.
• In case 20, the provider started the patient on lisinopril for chronic kidney
disease.75 For at least six months, the provider did not reassess the patient’s
71 Emergency related deficiencies occurred in cases 2, 11-12, 15, 17-18, 20-21 and 23. Significant deficiencies
occurred in cases 2, 15, 17 and 20.
72 Deficiencies in chronic care occurred in cases 1, 2, 7-8, 11, 16, 20 and 22. Three significant deficiencies occurred
in cases 8, 11 and 20.
73 Colitis is a medication condition of the intestines with inflammation, pain, and bleeding.
74 POLST, also known as Physicians Order for Life Sustaining Treatment, is a form used to specify health care
treatments during a medical emergency or end-of-life care.
75 Lisinopril is a blood pressure medication. It can adversely affect the kidneys and increase potassium levels.
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compliance with lisinopril, assess for side effects, or document review of follow-
up blood pressure readings.
The most frequent chronic care diagnosis was substance use disorder in patients on
medication assisted treatment (MAT). The headquarters ISUDT team often managed these
cases; however, due to frequent ISUDT team delays, the SCC providers also managed MAT.
Please see the Clinician On-site section below for further discussion on ISUDT and patient
population details.
Specialty Services
OIG clinicians identified 21 provider performance deficiencies related to specialty services,
eight of which were significant.76 SCC providers often referred patients for specialty
consultations and endorsed specialty consultation reports timely; however, we identified 15
deficiencies involving providers ordering specialty services with priority time frames that
were not appropriate for the patients’ medical conditions. In seven of these deficiencies, the
specialists made recommendations, but the providers did not follow them and did not
document the medical rationale for not doing so. The following are examples of significant
deficiencies:
• In case 11, the patient had an abnormal chest CT that showed a large anterior
mediastinal mass.77 The specialist recommended a PET/CT scan to determine
whether hypermetabolic activity in the mass was present, which would indicate
cancer activity.78 The provider did not order this urgently needed PET/CT scan
until nearly four months later and did not discuss the specialist’s
recommendation with the patient until that appointment. When the provider
addressed the CT results with the patient, the provider ordered the PET/CT
scan as medium-priority time frame instead of high-priority, as was medically
indicated. This further delayed care and increased the patient’s risk of the
cancer to spread.
• In case 13, the provider saw the patient for hospital return in which the patient
had been diagnosed with patent foramen ovale and stroke.79 The hospital
records contained discrepant and incomplete information about the duration of
the specialist’s recommended blood-thinning medication (Eliquis) and the
hospital records requested a neurology specialist follow-up within one month to
help manage this complex patient. Instead, the SCC provider ordered a medium-
priority time frame neurology referral due approximately six weeks after the
patient’s hospital discharge and did not timely address the Eliquis discrepancy.
• In case 20, the provider endorsed a patient’s right hand x-ray. The x-ray showed
a recent bone fracture with angulation and displacement and the bone had
shortened due to the fracture fragments overlapping. The next day, the provider
ordered the orthopedic surgery referral as medium-priority, due within 45 days,
instead of emergent or high-priority time frame, which was medically indicated.
76 Provider performance specialty services deficiencies occurred in cases 1, 11-15, 18, 20-21, 26 and 28. Eight
significant deficiencies occurred in cases 11, 13, and 20-21.
77 Abnormal growths were located in the front portion of the chest, between the lungs.
78 A positron emission tomography (PET) scan is an imaging test of organs and soft tissues.
79 Patent foramen ovale is a hole in the heart muscle that allows blood to inappropriately flow from the right to left
atria, which shunts some blood flow from the lungs to the rest of the body.
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Furthermore, medical leadership approved the referral for this inappropriate
time frame. Because the orthopedic surgery consultation occurred 21 days after
the injury, partial healing had occurred, and the surgeon was unable to non-
surgically reduce the displaced fracture. As a result, the patient subsequently
required orthopedic surgery.
• In case 21, the provider ordered a neck CT scan for a patient with a neck abscess
with a medium-priority time frame, with a compliance date of six weeks later.
The CT scan should have been completed emergently for the infection; however,
the patient did not receive the CT scan until after the patient worsened 15 days
later and required hospitalization.
• Further in case 21, the provider evaluated the patient with a six-month history
of recurrent neck abscesses. The provider documented more new lesions and
purulent drainage.80 The provider documented an infectious disease specialist
consult was necessary but ordered the referral with a medium-priority time
frame, to be completed in six weeks. Considering the high-risk location of the
patient’s neck lesions, their frequent recurrence, and the delayed healing, the
provider should have ordered the referral with high-priority or at least
requested a sooner electronic specialty services consultation, pending the in-
person infectious disease appointment.
Documentation Quality
Documentation is important because it shows the provider’s thought process during clinical
decision making and allows future caregivers to understand the patient’s management and
plan of care. Although providers usually documented well, OIG clinicians identified 26
documentation deficiencies. Providers sometimes did not update problem lists, and
consequently, important errors in outpatient documentation occurred.81 In addition,
providers did not always document clinically relevant information when contacted by nurses
for emergencies or co-consultation as in the following:
• In case 2, providers evaluated the patient in the TTA, but no providers
documented progress notes for the significant emergency events.
Patient Notification Letters
Providers usually sent patient notification letters to patients; however, the letters frequently
did not contain the four elements required by policy. We discuss this further in the
Diagnostic Services and Health Information Management indicators.
Provider Continuity
Patients generally received good provider continuity. Providers were assigned to specific
clinics or fire camps to ensure continuity of care.
80 Purulent drainage is a thick, opaque fluid that usually indicates an infected wound.
81 Documentation deficiencies occurred in cases 1-2, 7, 11-13, 15, 17-18, 20-21, and 23. Significant deficiencies
occurred in case 2.
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Clinician On-Site Inspection
OIG clinicians met with the medical leadership and providers to discuss patient care. SCC had
a new chief executive officer (CEO), who had served at other CCHCS institutions. The chief
medical executive (CME) had been in place for several years, including during the Cycle 6
inspection. A new chief physician and surgeon (CP&S) had been in place for approximatively
one year and served as an SCC line physician prior to the promotion. During the review
period, SCC had six providers, consisting of three physicians and three nurse practitioners
(NPs). One NP was responsible for and travelled to treat off-site fire camp patients. One
CCHCS headquarters telemedicine NP, the remaining on-site NP, and the physicians all
supported the SCC clinics. One new physician was in the process of onboarding. All on-site
providers took overnight calls and rotations in the TTA.
Leadership reported after the SCC Cycle 6 inspection, California Correctional Center (CCC)
closed. SCC became a hub for CCC’s 14 fire camps and all associated incarcerated persons, as
well as some of CCC’s institution patients.
OIG clinicians spoke to medical leadership and providers about various aspect of patient
care. Medical leadership discussed the implementation and effects of the ISUDT program. We
also discussed the ordering of time priority of specialty referrals. In our case reviews, we
identified how the providers ordered most of the specialty services referrals as medium-
priority or routine-priority, regardless of medical indication for a higher priority. However,
we also found most medium-priority referrals that should have been high-priority actually
resulted in specialty appointments occurring within or near a high-priority timeframe. When
we inquired about this, providers stated, if they know a high-priority referral will likely not
result in an appointment within the 14-day compliance timeframe, they will order the
referral as medium-priority, regardless of medical need. Medical leadership stated SCC has a
system to ensure medium-priority and routine-priority specialty services are ordered as
quickly as possible.
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Recommendations
• Medical leadership should identify the root cause(s) for poor provider care of
medically complex patients and should implement remedial measures as
appropriate.
• Medical leadership should develop and implement strategies to ensure patients
receive specialty services within priority time frames appropriate to their
medical conditions.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluate the quality of care in the specialized medical
housing units. We evaluate the performance of medical staff in assessing, monitoring, and
intervening for medically complex patients requiring close medical supervision. Our
inspectors also evaluate the timeliness and quality of provider and nursing intake
assessments and care plans. We assess staff members’ performance in responding promptly
when patients’ conditions deteriorate and look for good communication when staff consult
with one another while providing continuity of care.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Not Applicable
At the time of our inspection, SCC had no specialized medical housing unit.
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Compliance Score Results
Table 16. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Did the registered nurse complete an initial
N/A N/A N/A N/A
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
N/A N/A N/A N/A
required time frame? (13.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient N/A N/A N/A N/A
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call N/A N/A N/A N/A
system? (13.101)
For specialized health care housing (CTC, SNF, hospice, OHU): Do health
care staff perform patient safety checks according to institution’s local N/A N/A N/A N/A
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): N/A
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. The OIG clinicians
focused on the institution’s performance in providing needed specialty care. Our clinicians
also examined specialty appointment scheduling, providers’ specialty referrals, and medical
staff’s retrieval, review, and implementation of any specialty recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (80.1%)
Case review found SCC generally provided satisfactory specialty services for its patients.
Specialty service appointments occurred as ordered and nurses frequently assessed patients
appropriately upon return from off-site medical appointments. However, we identified
providers ordering specialty referrals with time frames not appropriate for the patients’
medical conditions. Staff also often retrieved specialty documents; however, some misfiling
occurred. Considering all factors, the OIG rated the case review component of this indicator
adequate.
Compliance testing showed mixed results in this indicator. Preapproved specialty services for
newly arrived patients only intermittently occurred within required time frames, while
performance in retrieving specialty reports and the timeliness of provider endorsements
varied. Based on the overall Specialty Services compliance score result, the OIG rated the
compliance testing component of this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 105 events related to specialty services; 82 were specialty
consultations and procedures. We identified 31 deficiencies in this category, 10 of which
were significant.82 An additional 19 deficiencies related to providers either not ordering
necessary specialty services or ordering the services for inappropriate priority levels.
Access to Specialty Services
SCC’s performance in this area was mixed. Compliance testing showed SCC staff offered
excellent access for high-priority and routine-priority specialty appointments (MIT 14.001,
93.3% and MIT 14.007, 93.3%) and very good access for medium-priority specialty
appointments (MIT 14.004, 80.0 %). However, staff needed improvement in completing
preapproved specialty appointments for patients transferring into SCC (MIT 14.010, 61.5%).
OIG clinicians reviewed 82 specialty consultations and procedures and found most specialty
appointments occurred timely. We found six deficiencies, five of which were significant.83
82 Deficiencies occurred in cases 1, 12-15, 18, and 20-22. Significant deficiencies occurred in cases 12-15 and 21.
83 Deficiencies occurred in cases 1, 12, 14, and 21. Significant deficiencies occurred in cases 12, 14, and 21.
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Three deficiencies involved delayed specialty service consultations, two of which were
significant:
• In case 14, the patient underwent a right kidney removal for renal cancer almost
two months late. This increased the patient’s risk of the cancer spreading.
• In case 21, the patient’s appointment with CCHCS addiction medicine central
team follow-up appointment did not occur. The addiction specialist cancelled
the order and deferred the appointment back to the provider due to the backlog
in the addiction medicine central team appointments, delaying specialty care to
this patient.
The three other significant deficiencies involved SCC staff not reconciling specialty services
orders upon a patient’s hospital return, delaying or omitting care to the patient. The
following examples all occurred in Case 12:
• The patient’s endocrinology specialty referral to manage both
hyperparathyroidism and medication was cancelled due to patient’s hospital
admission. SCC staff did not reconcile or reorder this referral when the patient
returned to SSC after the hospitalization.84 The patient was not evaluated by
endocrinology specialty for hyperparathyroidism management as needed.
• Prior to the same hospital admission, the patient had an ENT specialist
appointment for hyperparathyroidism surgical evaluation. The order was
cancelled automatically when the patient was admitted to the hospital and SCC
staff did not reconcile or reorder this missed appointment when the patient
returned to SSC after the hospitalization.
• Two weeks after the above hospitalization, a provider ordered the ENT specialty
follow-up appointment. However, the patient was again admitted to the hospital;
consequently, the ENT specialty follow-up appointment was cancelled. Again,
upon the patient’s return, staff did not reconcile or order the missed ENT
specialty appointment. This specialty follow-up appointment then occurred
over seven weeks late, delaying specialty care for this patient.
Provider Performance
SCC provider performance in specialty services was mixed. Compliance testing revealed SCC needed
improvement in ensuring provider follow-up appointments after specialty appointments occurred
within required time frames (MIT 1.008, 69.1%). In addition to medium-priority and routine-priority
specialty referrals, OIG clinicians reviewed approximately 14 high-priority specialty referrals related
to follow-up provider appointments and identified four deficiencies, none of which were significant.
OIG clinicians found providers often did not order specialty services for medically appropriate time
frames, did not always follow the specialists’ recommendations, and did not document the medical
rationale. We identified 19 such deficiencies, eight of which were significant. For high-priority
specialty referrals, patients need to see their primary care provider within five days of completion of
84 Endocrinology is a medical specialty involving the evaluation and management of glandular and hormonal
conditions, including diabetes mellitus and thyroid diseases. Hyperparathyroidism is a condition in which the
parathyroid glands in the neck produce excess parathyroid hormone. This results in increased calcium levels in the
blood, weakened bones, and the formation of kidney stones.
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the specialty referral appointment. However, OIG clinicians found providers scheduled medium- and
routine-priority referral follow-up instead. As discussed in more detail in the Provider Performance
indicator, this provider referral pattern may delay specialty care to the patient and may also affect the
system’s automatic trigger to schedule the SCC provider follow-up appointment within five days. This
may delay or prevent patients from receiving timely provider follow-up with specialist’s
recommendations. In addition, this referral pattern may alter the required medical hold for high-
priority referrals, increasing the patient’s risk of erroneous transfer to another institution, potentially
in the midst of urgent medical care.
Nursing Performance
SCC nurses performed satisfactorily in assessing patients who returned to the facility from
off-site specialty service appointments. Nursing performed 23 assessments for patients
returning from specialty appointments and usually assessed patients appropriately,
contacted providers as needed, and appropriately entered follow-up orders. OIG clinicians
identified seven deficiencies, two of which were significant as follows:85
• In case 13, the RN assessed the patient after a high-priority specialty orthopedic
appointment. The RN ordered a 14-day follow-up appointment with the primary
care provider. However, the RN should have ordered a five-day follow-up
following the high-priority specialty orthopedic appointment.
• In case 21, the RN assessed the patient after return from a specialty consultation
for recurrent neck abscesses. The RN signed the documents with the specialist’s
recommendations but did not consult a provider. Instead, the RN ordered a
provider follow-up appointment in 14 days, delaying implementation of
specialty recommendations for the patient.
Health Information Management
Compliance testing revealed SCC performed satisfactorily in timely receipt and review of
medium-priority specialty reports (MIT 14.005, 76.9%); however, SCC needed improvement
in timely receipt and review of routine- and high-priority specialty reports specialty reports
(MIT 14.008, 53.3% and MIT 14.002, 73.3%). Staff needed further improvement in timely
scanning specialty documents into the patients’ medical records (MIT 4.002, 73.3%). OIG
clinicians reviewed 82 specialty consultations and procedures, identifying 13 health
information management deficiencies, three of which were significant. Most related to
misfiled or mislabeled consultation reports or to staff not timely retrieving consultation
progress notes. Notably, providers often endorsed the specialty service reports timely, once
they were received. We also discuss these deficiencies in the Health Information
Management indicator.
Clinician On-Site Inspection
We discussed the specialty services processes with SCC medical leadership, health
information management (HIM) supervisors, specialty nursing, ancillary staff, and
providers. HIM is responsible for collecting and scanning specialty services consultation
reports as discussed in the Health Information Management indicator.
85 Deficiencies occurred in cases 12, 13, 15, 18, and 21. Significant deficiencies occurred in cases 13 and 21.
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SCC leadership reported a significant backlog of CCHCS headquarters Integrated Substance
Use Disorder Treatment (ISUDT) follow-up appointments due to the ISUDT providers
reportedly being often unable to meet compliance time frames combined with the severe
backlog of the mental health licensed clinical social workers (LCSWs) who perform ISUDT
screenings. On-site providers were to treat the patients for substance use disorder prior to
receiving the LCSW assessment.
SCC medical staff reported fire camp patients from all but the closest camps had a high rate
of refusing specialty appointments. As discussed in Diagnostic Services, patients from the
more distant camps refused specialty appointments that required an overnight stay at SCC
due to the prevalence of violence between incarcerated residents. Medical staff attributed
the high violence rate in part to SCC incarcerated being non-designated, meaning they are
housed by general population and not separated by gang affiliation. Informal incarcerated
gang leaders on the yards (colloquially referred to as “shot callers”) will demand “payments”
from all incarcerated persons arriving at SCC, regardless of length of stay. If the new arrival
does not comply, they need to fight to protect themselves and risk being harmed. To improve
both safety and compliance with specialty appointments, SCC leadership is piloting a
potential solution of housing distant incarcerated patients at a camp closer to SCC, allowing
them to transport those campers into and out of SCC only for the day of the specialty
appointment. SCC staff reported the politics of violence does not extend into the fire camps.
When discussing providers’ pattern of ordering specialty referrals for medically
inappropriate priority time frames, medical leadership stated SCC has systems in place to
ensure medium- and routine-priority specialty services are ordered as quickly as possible,
regardless of the ordered compliance date. We discuss further in the Provider Performance
Indicator.
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Compliance Score Results
Table 17. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within 14 calendar
days of the primary care provider order or the Physician Request for 14 1 0 93.3%
Service? (14.001)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 11 4 0 73.3%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 8 1 6 88.9%
(14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or Physician Request for 12 3 0 80.0%
Service? (14.004)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 10 3 2 76.9%
frame? (14.005)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 7 0 8 100%
(14.006)
Did the patient receive the routine-priority specialty service within 90
calendar days of the primary care provider order or Physician Request for 14 1 0 93.3%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 8 7 0 53.3%
frame? (14.008)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 9 1 5 90.0%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
8 5 0 61.5%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Did the institution deny the primary care provider’s request for specialty
2 0 0 100%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
1 1 0 50.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 80.1%
Source: The Office of the Inspector General medical inspection results.
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Table 18. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up visits
29 13 3 69.1%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
22 8 15 73.3%
within five calendar days of the encounter date? (4.002)
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Health care leadership should determine the root cause(s) of untimely
preapproved specialty appointments for transfer-in patients and implement
appropriate remedial measures.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care administrative processes.
Our inspectors examined the timeliness of the medical grievance process and checked
whether the institution followed reporting requirements for adverse or sentinel events and
patient deaths. Inspectors checked whether the Emergency Medical Response Review
Committee (EMRRC) met and reviewed incident packages. We investigated and determined
whether the institution conducted required emergency response drills. Inspectors also
assessed whether the Quality Management Committee (QMC) met regularly and addressed
program performance adequately. In addition, our inspectors determined whether the
institution provided training and job performance reviews for its employees. We checked
whether staff possessed current, valid professional licenses, certifications, and credentials.
The OIG rated this indicator solely based on the compliance score. Our case review clinicians
do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining the
institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (67.4%)
SCC’s performance was mixed in this indicator. While SCC scored well in some applicable
tests, it needed improvement in several areas. The EMMRC rarely completed the required
checklists or reviewed the cases within required time frames. In addition, staff conducted
medical emergency response drills with incomplete documentation or without the required
emergency response drill forms. Physician managers only occasionally completed annual
performance appraisals in a timely manner. Lastly, the nurse educator did not ensure all
newly hired nurses received the required onboarding training and only intermittently
ensured nurses who administer medications timely complete their annual competency
testing. These findings are set forth in the table on the next page. Based on the overall
Administrative Operations compliance score result, the OIG rated this indicator
inadequate.
Compliance Testing Results
Nonscored Results
At SCC, the OIG did not have any applicable adverse sentinel events requiring root cause
analysis during our inspection period (MIT 15.001).
We obtained CCHCS Mortality Case Review reporting data. In our inspection, for one
applicable patient, we found no evidence in the submitted documentation the preliminary
mortality report had been completed. This report was overdue at the time of the OIG’s
inspection (MIT 15.998).
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Compliance Score Results
Table 19. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the This is a nonscored test. Please refer to the
institution meet RCA reporting requirements? (15.001) discussion in this indicator.
Did the institution’s Quality Management Committee (QMC) meet monthly?
6 0 0 100%
(15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
1 2 9 33.3%
packages the committee reviewed include the required documents?
(15.003)
For institutions with licensed care facilities: Did the Local Governing Body
(LGB) or its equivalent meet quarterly and discuss local operating N/A N/A N/A N/A
procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during each
watch of the most recent quarter, and did health care and custody staff 0 3 0 0
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
1 0 0 100%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
5 4 1 55.6%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
1 4 0 20.0%
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 9 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 6 0 1 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 1 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
0 1 0 0
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG medical This is a nonscored test. Please refer to Table 3
inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 67.4%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to review
CCHCS policies and procedures, relevant court orders, and guidance developed by the
American Correctional Association. We also reviewed professional literature on correctional
medical care; reviewed standardized performance measures used by the health care
industry; consulted with clinical experts; and met with stakeholders from the court, the
receiver’s office, the department, the Office of the Attorney General, and the Prison Law
Office to discuss the nature and scope of our inspection program. With input from these
stakeholders, the OIG developed a medical inspection program that evaluates the delivery of
medical care by combining clinical case reviews of patient files, objective tests of compliance
with policies and procedures, and an analysis of outcomes for certain population-based
metrics.
We rate each of the quality indicators applicable to the institution under inspection based on
case reviews conducted by our clinicians or compliance tests conducted by our registered
nurses. Figure A–1 below depicts the intersection of case review and compliance.
Figure A–1. Inspection Indicator Review Distribution for SCC
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of its
stakeholders, which continues in the Cycle 7 medical inspections. Below, Table A–1 provides
important definitions that describe this process.
Table A–1. Case Review Definitions
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The OIG eliminates case review selection bias by sampling using a rigid methodology. No
case reviewer selects the samples he or she reviews. Because the case reviewers are
excluded from sample selection, there is no possibility of selection bias. Instead, nonclinical
analysts use a standardized sampling methodology to select most of the case review samples.
A randomizer is used when applicable.
For most basic institutions, the OIG samples 20 comprehensive physician review cases. For
institutions with larger high-risk populations, 25 cases are sampled. For the California Health
Care Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected institution and from
CCHCS. Our analysts then apply filters to identify clinically complex patients with the highest
need for medical services. These filters include patients classified by CCHCS with high
medical risk, patients requiring hospitalization or emergency medical services, patients
arriving from a county jail, patients transferring to and from other departmental institutions,
patients with uncontrolled diabetes or uncontrolled anticoagulation levels, patients
requiring specialty services or who died or experienced a sentinel event (unexpected
occurrences resulting in high risk of, or actual, death or serious injury), patients requiring
specialized medical housing placement, patients requesting medical care through the sick
call process, and patients requiring prenatal or postpartum care.
After applying filters, analysts follow a predetermined protocol and select samples for
clinicians to review. Our physician and nurse reviewers test the samples by performing
comprehensive or focused case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the clinicians review
medical records, they record pertinent interactions between the patient and the health care
system. We refer to these interactions as case review events. Our clinicians also record
medical errors, which we refer to as case review deficiencies.
Deficiencies can be minor or significant, depending on the severity of the deficiency. If a
deficiency caused serious patient harm, we classify the error as an adverse event. On the
next page, Figure A–2 depicts the possibilities that can lead to these different events.
After the clinician inspectors review all the cases, they analyze the deficiencies, then
summarize their findings in one or more of the health care indicators in this report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and compliance
inspectors. Analysts follow a detailed selection methodology. For most compliance questions,
we use sample sizes of approximately 25 to 30. Figure A–3 below depicts the relationships
and activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT) questions to
determine the institution’s compliance with CCHCS policies and procedures. Our nurse
inspectors assign a Yes or a No answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain information, allowing
them to answer most of the MIT questions. Our regional nurses visit and inspect each
institution. They interview health care staff, observe medical processes, test the facilities and
clinics, review employee records, logs, medical grievances, death reports, and other
documents, and obtain information regarding plant infrastructure and local operating
procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for each of the questions
applicable to a particular indicator, then averages the scores. The OIG continues to rate these
indicators based on the average compliance score using the following descriptors: proficient
(85.0 percent or greater), adequate (between 84.9 percent and 75.0 percent), or inadequate
(less than 75.0 percent).
Indicator Ratings and the Overall Medical
Quality Rating
The OIG medical inspection unit individually examines all the case review and compliance
inspection findings under each specific methodology. We analyze the case review and
compliance testing results for each indicator and determine separate overall indicator
ratings. After considering all the findings of each of the relevant indicators, our medical
inspectors individually determine the institution’s overall case review and compliance
ratings.
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Appendix B: Case Review Data
Table B–1. SCC Case Review Sample Sets
Sample Set Total
Death Review/Sentinel Events 1
Diabetes 3
Emergency Services – CPR 2
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 5
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 12
Specialty Services 5
40
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Table B–2. SCC Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 5
Anticoagulation 2
Arthritis/Degenerative Joint Disease 1
Asthma 4
Cancer 2
Cardiovascular Disease 1
Chronic Kidney Disease 1
Chronic Pain 8
Coccidioidomycosis (Valley Fever) 1
COPD 2
COVID-19 1
Diabetes 4
Gastroesophageal Reflux Disease (GERD) 5
Gastrointestinal Bleed 1
Hepatitis C 7
Hyperlipidemia 6
Hypertension 8
Mental Health 6
Migraine Headaches 1
Rheumatological Disease 1
Seizure Disorder 2
Sleep Apnea 1
Substance Abuse 17
87
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Table B–3. SCC Case Review Events by Program
Diagnosis Total
Diagnostic Services 117
Emergency Care 73
Hospitalization 34
Intrasystem Transfers In 9
Intrasystem Transfers Out 6
Outpatient Care 359
Specialty Services 126
724
Table B–4. SCC Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 20
MD Reviews Focused 0
RN Reviews Detailed 10
RN Reviews Focused 20
Total Reviews 50
Total Unique Cases 40
Overlapping Reviews (MD & RN) 10
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Appendix C: Compliance Sampling Methodology
Sierra Conservation Center
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least one
Patients condition per patient — any risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 32 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 25 OIG Q: 4.005 • See Health Information Management
Community (Medical Records) (returns from
Hospital community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 4 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001 – 003 Radiology 10 Radiology Logs • Appointment date
(90 days – 9 months)
• Randomize
• Abnormal
MITs 2.004 – 006 Laboratory 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 0 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 32 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 25 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 25 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 8 OIG inspector • Identify and inspect all on-site clinical
MITs 5.107 – 111 on-site review areas
Transfers
MITs 6.001 – 003 Intrasystem Transfers 25 SOMS • Arrival date (3 – 9 months)
• Arrived from (another departmental
facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 10 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 • See Access to Care
Medication • At least one condition per patient —
any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of IPs tested in
MIT 7.001
MIT 7.003 Returns From 25 OIG Q: 4.005 • See Health Information Management
Community Hospital (Medical Records) (returns from
community hospital)
MIT 7.004 RC Arrivals — N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 4 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies OIG inspector • Identify and inspect clinical & med
Areas by test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site clinical
Preparation and by test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 9 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit 10 On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications medication listing medications for IPs housed in
restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001 – 007 Recent Deliveries N/A at this OB Roster • Delivery date (2 – 12 months)
institution • Most recent deliveries (within date
range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2 – 12 months)
institution • Earliest arrivals (within date range)
Preventive Services
MITs 9.001 – 002 TB Medications 25 Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months
or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever N/A at this Cocci transfer • Reports from past 2 – 8 months
institution status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Cycle 7, Sierra Conservation Center | 107
Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 007 RC N/A at this SOMS • Arrival date (2 – 8 months)
institution • Arrived from (county jail, return from
parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001 – 003 Specialized Health N/A at this CADDIS • Admit date (2 – 8 months)
Care Housing Unit institution • Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
• Rx count
• Randomize
MITs 13.101 – 102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, radiology, follow-up
wound care / addiction medication,
narcotic treatment program, and
transgender services
• Randomize
MITs 14.004 – 006 Medium-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, radiology, follow-up
wound care/addiction medication,
narcotic treatment program, and
transgender services
• Randomize
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7, Sierra Conservation Center | 108
Quality No. of
Indicator Sample Category Samples Data Source Filters
Specialty Services (continued)
MITs 14.007 – 009 Routine-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy,
ophthalmology, optometry, oral
surgery, physical therapy, physiatry,
podiatry, radiology, follow-up
wound care/addiction medication,
narcotic treatment program, and
transgender services
• Randomize
MIT 14.010 Specialty Services 13 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 2 InterQual • Review date (3 – 9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events events report (2 – 8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 12 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB N/A at this LGB meeting • Quarterly meeting minutes
institution minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
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Cycle 7, Sierra Conservation Center | 109
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations (continued)
MIT 15.103 Death Reports 1 Institution-list of • Most recent 10 deaths
deaths in prior Initial death reports
12 months
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 5 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 9 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site certification • All staff
Response tracking logs • Providers (ACLS)
Certifications • Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
MIT 15.109 Pharmacy and All On-site listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
document
MIT 15.110 Nursing Staff New All Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998 CCHCS Mortality 1 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
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California Correctional Health Care Services’
Response
Office of the Inspector General, State of California Inspection Period: March 2024 – August 2024 Report Issued: December 2025
Cycle 7
Medical Inspection Report
for
Sierra Conservation Center
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Shaun Spillane
Chief Deputy Inspector General
STATE of CALIFORNIA
December 2025
OIG