OIG
Valley State Prison Cycle 6 Medical Inspection Report
Read the report at CDCR ↗
Roy W. Wesley, Inspector General Bryan B. Beyer, Chief Deputy Inspector General
OFFICE of the
OIG
INSPECTOR GENERAL
Independent Prison Oversight August 2020
Cycle 6
Medical Inspection
Report
Valley
State Prison
Electronic copies of reports published by the Office of the Inspector General
are available free in portable document format (PDF) on our website.
We also offer an online subscription service.
For information on how to subscribe,
visit www.oig.ca.gov.
For questions concerning the contents of this report,
please contact Shaun Spillane, Public Information Officer,
at 916-255-1131.
Return to Contents
Valley State Prison iii
Contents
Introduction 1
Summary 3
Overall Rating: Adequate 3
Medical Inspection Results 7
Deficiencies Identified During Case Review 7
Case Review Results 7
Compliance Testing Results 8
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 13
Access to Care 13
Diagnostic Services 18
Emergency Services 21
Health Information Management 24
Health Care Environment 29
Transfers 34
Medication Management 39
Preventive Services 46
Nursing Performance 47
Provider Performance 51
Specialized Medical Housing 55
Specialty Services 58
Administrative Operations 63
Appendix A: Methodology 65
Case Reviews 66
Compliance Testing 69
Indicator Ratings and the Overall Medical Quality Rating 70
Appendix B: Case Review Data 71
Appendix C: Compliance Sampling Methodology 74
California Correctional Health Care Services’ Response 81
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
iv Cycle 6 Medical Inspection Report
Illustrations
Tables
1. VSP Summary Table 3
2. VSP Policy Compliance Scores 4
3. VSP Master Registry Data as of April 2019 5
4. VSP Health Care Staffing Resources as of April 2019 6
5. VSP Results Compared With State HEDIS Scores 10
6. Access to Care 16
7. Other Tests Related to Access to Care 17
8. Diagnostic Services 20
9. Health Information Management 27
10. Other Tests Related to Health Information Management 28
11. Health Care Environment 33
12. Transfers 37
13. Other Tests Related to Transfers 38
14. Medication Management 44
15. Other Tests Related to Medication Management 45
16. Preventive Services 46
17. Specialized Medical Housing 57
18. Specialty Services 61
19. Other Tests Related to Specialty Services 62
20. Administrative Operations 64
A–1. Case Review Definitions 66
B–1. Case Review Sample Sets 71
B–2. Case Review Chronic Care Diagnoses 72
B–3. Case Review Events by Program 73
B–4. Case Review Sample Summary 73
Figures
A–1. Inspection Indicator Review Distribution for VSP 65
A–2. Case Review Testing 68
A–3. Compliance Sampling Methodology 69
Photographs
1. Shaded Outdoor Waiting Area With a Mist Cooling System 29
2. Indoor Waiting Area With Open Seating 30
3. Examination Table With Insufficient Space for a Patient to Lie Down 30
4. Expired Medical Supplies Dated December 2018 31
5. Torn Sterile Packaging 31
Cover: Rod of Asclepius courtesy of Thomas Shafee
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of
the Inspector General (OIG) is responsible for periodically reviewing
and reporting on the delivery of the ongoing medical care provided to
incarcerated persons in the California Department of Corrections and
Rehabilitation (the department).1
In Cycle 6, the OIG continues to apply the same assessment
methodologies used in Cycle 5, including clinical case review and
compliance testing. These methods provide an accurate assessment of
how the institution’s health care systems function regarding patients
with the highest medical risk who tend to access services at the highest
rate. This information helps to assess the performance of the institution
in providing sustainable, adequate care.2
We continue to review institutional care using 15 indicators, as in prior
cycles. Using each of these indicators, our compliance inspectors collect
data in answer to compliance- and performance-related questions
as established in the medical inspection tool (MIT).3We determine a
total compliance score for each applicable indicator and consider the
MIT scores in the overall conclusion of the institution’s performance. In
addition, our clinicians complete document reviews of individual cases
and also perform on-site inspections, which include interviews with staff.
In reviewing the cases, our clinicians examine whether providers used
sound medical judgment in the course of caring for a patient. In the
event we find errors, we determine whether such errors were clinically
significant or led to a significantly increased risk of harm to the patient.4
At the same time, our clinicians examine whether the institution’s
medical system mitigated the error. The OIG rates the indicators as
proficient, adequate, or inadequate.
1. 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.
2. 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.
3. The department regularly updates its policies. The OIG updates our policy-compliance
testing to reflect the department’s updates and changes.
4. If we learn of a patient needing immediate care, we notify the institution’s chief
executive officer.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
2 Cycle 6 Medical Inspection Report
The OIG has adjusted Cycle 6 reporting in two ways. First, commencing
with this reporting period, we interpret compliance and case review
results together, providing a more holistic assessment of the care; and,
second, we consider whether institutional medical processes lead to
identifying and correcting provider or system errors. The review assesses
the institution’s medical care on both system and provider levels.
As we did during Cycle 5, our office is continuing to inspect both those
institutions remaining under federal receivership and those delegated
back to the department. There is no difference in the standards used for
assessing a delegated institution versus an institution not yet delegated.
At the time of the Cycle 6 inspection of Valley State Prison (VSP), the
receiver had delegated this institution back to the department.
We completed our sixth inspection of VSP, and this report presents
our assessment of the health care provided at that institution during
the inspection period between September 2018 and April 2019.5
Notably, our report of VSP was not impacted by the novel coronavirus
disease pandemic (COVID-19). The data we obtained for VSP predates
COVID-19, so neither case review nor compliance testing were affected.
Similarly, the on-site regional nurse review was not impacted by COVID-19.
VSP is located in Chowchilla, houses primarily Level II General
Population incarcerated persons and those requiring Sensitive Needs
Yard (SNY) placements. VSP is designated as a basic care institution,
providing general medical care through its five medical clinics which
handle nonurgent requests for medical services. Patients needing urgent
or emergent care are treated in its triage and treatment area (TTA).
Additional services are provided in the outpatient housing unit (OHU),
through special services, and via telemedicine. VSP provides care to
patients in the mental health delivery system at the Enhanced Outpatient
Program (EOP) and serves as a reentry hub for incarcerated persons for
needs-based rehabilitative services.
5. Samples are obtained per the case review methodology shared with stakeholders in
prior cycles. The case reviews include death reviews that occurred between April 2018
and February 2019, emergency cardiopulmonary resuscitation (CPR) reviews between
May 2018 and January 2019, transfer reviews between August 2018 and February 2019,
and correctional treatment center (CTC) reviews between August 2018 and February 2019.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 3
Summary
We completed the Cycle 6 inspection of Valley
State Prison (VSP) in August 2019. OIG inspectors
Overall
monitored the institution’s delivery of medical care
that occurred between September 2018 and April 2019. Rating
The OIG rated the overall quality of health care at Adequate
VSP as adequate. We list the individual indicators and
ratings applicable for this institution in Table 1 below.
Table 1. VSP Summary Table Ratings
Proficient Adequate Inadequate
Cycle 6 Ratings Change
Since
Health Care Indicators Case Review Compliance Overall Cycle 5 *
Access to Care
Diagnostic Services
Emergency Services N/A
Health Information Management
Health Care Environment N/A
Transfers
Medication Management
Prenatal and Postpartum Care N/A N/A N/A N/A
Preventive Services N/A
Nursing Performance N/A
Provider Performance N/A
Reception Center N/A N/A N/A N/A
Specialized Medical Housing
Specialty Services
Administrative Operations † N/A
* The symbols in this column correspond to changes that occurred in indicator ratings between
the medical inspections conducted during Cycle 5 and Cycle 6. The equals sign means there
was no change in the rating. The single arrow means the rating rose or fell one level, and the
double arrow means the rating rose or fell two levels (green, from inadequate to proficient;
pink, from proficient to inadequate).
† Administrative Operations is a secondary indicator and is not considered when rating the
institution’s overall medical quality.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
4 Cycle 6 Medical Inspection Report
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 364 patient records and 1,002 data points and
observed VSP’s processes during an on-site inspection in April 2019.
They used the data to answer 88 policy questions. Table 2 below lists
VSP’s average scores from Cycles 4, 5, and 6.
OIG case review clinicians (a team of physicians and nurse consultants)
reviewed 57 cases, which contained 1,083 patient-related events. After
examining the medical records, our clinicians conducted a follow-
up on-site inspection in June 2019 to verify their initial findings. Of
the 1,083 individual health care events, the OIG clinicians identified
Table 2. VSP Policy Compliance Scores
Scoring Ranges
100% – 85% 84% – 75% 74% – 0
Medical Average Score
Inspection
Tool (MIT) Policy Compliance Category Cycle 4 Cycle 5 Cycle 6
1 Access to Care 66% 82% 92%
2 Diagnostic Services 81% 76% 63%
4 Health Information Management 57% 82% 76%
5 Health Care Environment 59% 82% 69%
6 Transfers 80% 89% 66%
7 Medication Management 73% 70% 70%
8 Prenatal and Postpartum Care N/A N/A N/A
9 Preventive Services 66% 76% 73%
12 Reception Center N/A N/A N/A
13 Specialized Medical Housing 94% 63% 83%
14 Specialty Services 84% 84% 89%
15 Administrative Operations 58% 83% 83%
* In Cycle 4, there were two secondary (administrative) indicators, and this score reflects
the average of those two scores. In Cycle 5 and moving forward, the two indicators
were merged into one, with only one score as the result.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 5
295 deficiencies. However, only 36 of these deficiencies were of such a
magnitude that our clinicians felt they resulted in potential significant
risk of harm to patients.
The OIG physicians rated the quality of care for 25 comprehensive
case reviews. Of these 25 cases, our clinicians rated 21 adequate
and four inadequate. Our clinicians found no adverse events during
this inspection.
The OIG then considered the results from both case review and
compliance testing, and drew overall conclusions, which we report in the
13 health care indicators.6 Multiple OIG physicians and nurses performed
quality control reviews; their subsequent collective deliberations ensured
consistency, accuracy, and thoroughness. Our clinicians acknowledged
institutional structures that catch and resolve mistakes which may occur
throughout the delivery of care. As noted above, we listed the individual
indicators and ratings applicable for this institution in Table 1, the
VSP Summary Table.
In April 2019, the Health Care Services Master Registry showed that VSP
had a total population of 3,080. A breakdown of the medical risk level
of the VSP population as determined by the department is set forth in
Table 3 below.
Table 3. VSP Master Registry Data as of April 2019
Medical Risk Level Number of Patients Percentage
High 1 108 3.5%
High 2 298 9.7%
Medium 1,611 52.3%
Low 1,063 34.5%
Total 3,080 100.0%
Source: Cycle 6 medical inspection preinspection questionnaire
staffing matrix received on April 1, 2019, from Valley State Prison.
6. The indicators for Reception Center and Prenatal Care do not apply to VSP.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
6 Cycle 6 Medical Inspection Report
Based on staffing data the OIG obtained from California Correctional
Health Care Services (CCHCS), as identified in Table 4 below, VSP had
2.5 vacant nurse supervisor positions, and five vacant nurse positions. At
the time of the OIG’s inspection, VSP had one primary care provider, one
nursing supervisor, and four nursing staff on extended leave.
Table 4. VSP Health Care Staffing Resources as of April 2019
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 6 7 10.5 107.7 131.2
Filled by Civil Service 6 8 8 102.6 124.6
Vacant 0 0 2.5 5.1 7.6
Percentage Filled by Civil Service 100% 114% 76.2% 95.3% 95.0%
Filled by Telemedicine 0 3 0 0 3
Percentage Filled by Telemedicine 0 42.86% 0 0 2.3%
Filled by Registry 0 1 0 6 7
Percentage Filled by Registry 0 14.3% 0 5.6% 5.3%
Total Filled Positions 6 12 8 108.6 134.6
Total Percentage Filled 100% 171.4% 76.2% 100.8% 102.6%
Appointments in Last 12 Months 0 2 0 22.6 24.6
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 1 1 4 6
Adjusted Total: Filled Positions 6 11 7 104.6 128.6
Adjusted Total: Filled Positions 100% 157.1% 66.7% 97.1% 98.0%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Note: The OIG does not independently validate staffing data received from the department.
Source: Cycle 6 medical inspection preinspection questionnaire staffing matrix received on July 30, 2019,
from Valley State Prison.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 7
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.7
Our inspectors did not find any adverse events at VSP during the
Cycle 6 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed
10 of the 13 indicators applicable to VSP. Of these 10 indicators, OIG
clinicians rated one proficient, seven adequate, and two inadequate.
The OIG physicians also rated the overall adequacy of care for each of
the 25 detailed case reviews they conducted. Of these 25 cases, 21 were
adequate and four were inadequate. In the 1,083 events reviewed, there
were 293 deficiencies, 36 of which the OIG clinicians considered to be
of such magnitude that, if left unaddressed, would likely contribute to
patient harm.
Our clinicians found the following strengths at VSP:
• The institution provided excellent overall access to providers
and nurses.
• Medical staff evaluated patients efficiently and appropriately in
emergency medical situations.
• The physician managers established a culture of collaboration
and communication. VSP’s providers felt well supported and
reported high morale.
Our clinicians found VSP could improve in the following areas:
• VSP providers should review records more reliably and
thoroughly, along with consistently documenting their
medical care.
• VSP staff should retrieve specialty reports on time. Staff should
reliably retrieve the physician discharge summary for patients
who received care at off-site hospitals and emergency rooms.
Providers should also sign specialty reports on time.
7. For a further discussion of an adverse event, see Table A–1.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
8 Cycle 6 Medical Inspection Report
• VSP nurses should dependably relay stat laboratory results to the
providers timely, preventing potential delays in care.
• Nurses should complete more thorough initial assessments for
newly arrived patients who transferred into the institution.
• Nurses and providers should review hospital discharge
recommendations thoroughly, preventing errors in the hospital
return process.
• VSP should improve medication processes, such as newly
prescribed medications, chronic care medication continuity,
hospital discharge medications, and medication continuity for
patients transferring into the institution.
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable
to VSP. Of these 10 indicators, our compliance inspectors rated two
proficient, three adequate, and five inadequate. In the Health Care
Environment, Preventive Services, and Administrative Operations
indicators, we tested policy compliance only, because how the institution
performed in these indicators usually does not significantly affect the
institution’s overall quality of patient care.
VSP demonstrated a high rate of policy compliance in the
following areas:
• Nurses received and reviewed sick call request forms and
conducted face-to-face evaluations within the required time
frames. In addition, there were enough supplies of sick call
request forms in the VSP housing units.
• VSP patients experienced timely chronic care appointments and
nurse-to-provider referrals. Patients returning from specialty
consultations saw their primary care providers promptly.
• The institution completed high-priority and routine-specialty
services within the required time frames.
VSP demonstrated a low rate of policy compliance in the
following areas:
• Providers often did not review radiology and laboratory reports
within the required time frames. Providers often communicated
diagnostic results late, and patient letters were often missing key
elements required by departmental policy.
• Patients did not always receive their chronic care medications
timely. There was poor medication continuity for patients who
transferred into VSP.
• Health care staff did not always follow universal hand
hygiene precautions.
• Nursing staff did not regularly inspect or inventory emergency
medical response bags.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 9
Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted
above, the OIG presents selected measures from the Healthcare
Effectiveness Data and Information Set (HEDIS) for comparison
purposes. The HEDIS is a set of standardized quantitative performance
measures designed by the National Committee for Quality Assurance
to ensure the public has the data it needs to compare the performance
of health care plans. Because the Veterans Administration no longer
publishes its individual HEDIS scores, we removed them from our
comparison for Cycle 6. Likewise, Kaiser (commercial plan) no longer
publishes HEDIS scores, but the OIG obtained Kaiser Medi-Cal HEDIS
scores through the California Department of Health Care Services’
Medi‑Cal Managed Care Technical Report to use in conducting our analysis,
and we present them here for comparison.
HEDIS Results
We considered VSP’s performance with population-based metrics to
assess the macroscopic view of the institution’s health care delivery.
VSP’s results compared favorably with those found in State health plans
for diabetic care measures. We list the five HEDIS measures in Table 5.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs (California
Medi-Cal, Kaiser Northern California (Medi-Cal), and Kaiser Southern
California (Medi-Cal) ), VSP outscored in four of the five diabetic
measures. The institution scored lower than Kaiser Southern California
(Medi-Cal) in eye examinations.
Immunizations
Statewide comparative data were not available for immunization
measures; however, we include these data for informational purposes.
VSP had a 71 percent immunization rate for adults 18 to 64 years old, and
a 97 percent immunization rate for adults 65 years of age and older. The
pneumococcal vaccination rate was 90 percent.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
10 Cycle 6 Medical Inspection Report
Table 5. VSP Results Compared With State HEDIS Scores
California California
VSP Kaiser Kaiser
California NorCal SoCal
Cycle 6 Medi-Cal Medi-Cal Medi-Cal
HEDIS Measure Results * 2018 † 2018 † 2018 †
HbA1c Screening 100% 87% 95% 95%
Poor HbA1c Control (> 9.0%) ‡,§ 6% 35% 24% 19%
HbA1c Control (< 8.0%) ‡ 86% 54% 63% 71%
Blood Pressure Control (< 140/90) ‡ 92% 66% 76% 85%
Eye Examinations 76% 61% 75% 84%
Influenza – Adults (18 – 64) 71% – – –
Influenza – Adults (65 +) 97% – – –
Pneumococcal – Adults (65 +) 90% – – –
Colorectal Cancer Screening 93% – – –
Notes and Sources
* Unless otherwise stated, data were collected in April 2019 by reviewing medical records from a
sample of VSP’s population of applicable patients. These random statistical sample sizes were based on
a 95 percent confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services
publication titled, Medi-Cal Managed Care External Quality Review Technical Report, dated
July 1, 2017 – June 30, 2018 (published April 2019).
‡ For this indicator, the entire applicable VSP 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 obtained from the CCHCS Master Registry.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 11
Recommendations
As a result of our assessment of VSP’s performance, we offer the
following recommendations to the department:
• The chief medical executive CME should audit and address
providers’ late reviews of diagnostic reports.
• The CNE should audit stat laboratory results to encourage
nurses to timely notify providers of the stat results.
• The CME and the chief physician and surgeon (CP&S) should
improve the monitoring of provider care to ensure the providers
are reviewing records thoroughly and documenting all their
medical decisions.
• The CME and the chief nursing executive (CNE) should regularly
perform audits of patients returning from off-site hospitals
to improve staff’s retrieval of physician discharge summaries
and to encourage providers and nurses to review discharge
records thoroughly.
• The CNE and nursing supervisors should improve the inventory
process to ensure emergency medical response bags (EMRBs) are
properly maintained.
• Medical staff should be retrained and reminded to follow
universal hand hygiene precautions. Implementing random spot
checks may help with compliance.
• The CNE should monitor the performance of reception
and receiving (R&R) nurses to ensure that complete nursing
assessments and proper interventions for newly arrived patients
occur. Implementing an electronic alert to encourage the
completion of electronic health records system (EHRS) electronic
nursing assessment forms may help.
• VSP medical leadership should examine and modify the
institution’s medication processes to ensure timely and
appropriate medication administration.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
12 Cycle 6 Medical Inspection Report
(This page left blank for reproduction purposes.)
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 13
Access to Care
Overall
Rating
In this indicator, OIG inspectors evaluated the institution’s ability to
Proficient
provide patients with timely clinical appointments. Our inspectors
reviewed the scheduling and appointment timeliness for newly arrived
Case Review
patients, sick calls, and nurse follow-ups. We examined referrals
Rating
to primary care providers, provider follow-ups, and specialists.
Proficient
Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization
Compliance
Score
Results Overview
Proficient
(92%)
VSP provided excellent access to care in most clinical areas, including
access to clinic providers, outpatient housing unit (OHU) providers,
nurses, and specialty services. The institution also did well with
follow-up after triage and treatment area (TTA) visits and demonstrated
acceptable access for patients requiring follow-up appointments after
returning from a hospital or off-site specialist. Access for patients
(especially high-risk patients) who recently transferred into VSP needed
improvement, as these patients were frequently not scheduled for
their initial provider intake appointments on time. Nonetheless, the
institution performed very well in most areas, resulting in a proficient
rating for this indicator.
Case Review Results
The OIG clinicians reviewed 314 provider, nurse, specialty, and hospital
events that required the institution to generate appointments. They
identified 18 opportunities for improvement relating to this indicator,
only two of which were significant.
Access to Clinic Providers
Access to clinic providers is an integral part of patient care in health
care delivery. Failure to ensure provider appointment availability can
cause lapses in care. VSP performed exceptionally well with access
to providers in both case review and compliance testing. Compliance
testing found chronic care follow-up occurred on time (MIT 1.001, 92%).
When sick call nurses referred their patients to a provider, the provider
saw patients timely (MIT 1.005, 87%). When providers ordered follow-ups
for sick call conditions, staff scheduled patients timely (MIT 1.006, 100%).
Our clinicians found two minor and two significant opportunities
for improvement in this area. The significant errors occurred when
nurses placed incorrect follow-up orders in the electronic health record
system (EHRS).8
8. Significant events occurred in cases 18 and 36.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
14 Cycle 6 Medical Inspection Report
Access to Specialized Medical Housing Providers
VSP performed extremely well with access in the OHU. When staff
admitted patients to the OHU, providers examined the patients promptly.
Providers evaluated and recorded progress notes within the appropriate
time frames. (MIT 13.003, 90%). Case review testing did not find any
deficiencies regarding access to OHU providers.
Access to Clinic Nurses
The institution’s nurses provided excellent access for nurse sick calls
and provider-to-nurse referrals. Our case reviewers did not identify
any opportunities for improvement related to clinic nurse access.
Compliance testing also showed excellent sick call access. Nurses
consistently reviewed sick call requests the same day they collected them
(MIT 1.003, 100%) and evaluated their patients with sick call symptoms
within one business day (MIT 1.004, 100%).
Access to Specialty Services
Compliance testing showed excellent specialty access for both
high-priority (MIT 14.001, 100%) and routine-priority (MIT 14.007, 100%)
referrals. When the specialist requested a follow-up appointment, the
institution scheduled the requested follow-up appointments timely
(MIT 14.003, 90%, and MIT 14.009, 75%). Case review testing confirmed
this good performance. Our clinicians found four minor delays in access
to specialty care9and one significant error in the case reviews:
• In case 22, the patient returned to VSP from a brief stay at
another institution. The institution did not reconcile the oral
maxillofacial surgery follow-up appointment order, and it was
not scheduled as ordered. Although the patient did not suffer any
complications, the failure to follow policy was significant. We
also discuss this error in the Specialty Services indicator.
Provider Follow‑Up After Specialty Service
VSP performed sufficiently in ensuring patients saw their providers
after specialty appointments. Although proficient overall, compliance
testing showed VSP still had room for improvement in this area
(MIT 1.008, 82%). Case review testing found one opportunity
for improvement:
• In case 27, the oncologist evaluated the patient for prostate
cancer and requested a seven-day oncology follow-up. Due to an
error in scheduling a follow-up appointment with the primary
provider after the specialty consultation, the patient saw his
provider 10 days later, and missed his specialist-recommended
follow-up appointment. This case had many delays in care
coordination that resulted in a six-month delay for the patient’s
prostate cancer treatment.
9. Minor delays in cases 18, 19, 26, and 27.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 15
Follow‑up After Hospitalization
Providers usually saw their patients promptly after patients returned
from an off-site hospital. Compliance testing showed minor problems
in this area (MIT 1.007, 90%). Case review testing showed issues with
patients returning from a hospital. More details are available in the
Transfers indicator.
Follow‑up After Urgent or Emergent Care (TTA)
VSP providers saw their patients promptly after they received urgent or
emergent care in the TTA. We found only three minor opportunities for
improvement, which were not clinically significant.10
Follow‑up After Transferring Into the Institution
VSP performed poorly with ensuring provider access for patients who
recently transferred into the institution. Although compliance testing
showed 80 percent of the sampled patients saw a provider on time
(MIT 1.002), only two of the five high-risk patients (40%) saw a provider
on time. It is essential that the institution provide access to providers to
high-risk patients. Case review analysis also revealed delays in two of the
eight cases in which patients transferred into the institution. Please see
the Transfers indicator for additional details.
Clinician On‑Site Inspection
Our clinicians attended provider meetings and morning huddles in which
staff reviewed patients who received overnight care, were hospitalized, or
were scheduled for off-site specialty care. Staff discussed and scheduled
patients with any urgent needs during these meetings.
VSP managers reported their recent difficulty with provider availability;
one of their providers was on extended sick leave, and another provider
was on vacation. The CME also presented data showing that VSP’s
patient population was at 145 percent of the institution’s capacity.
Furthermore, 14 percent of the patients carried a high-risk classification.
Although the CME maintained that the large numbers of patients
with significant medical needs negatively affected VSP’s ability to
provide access to care, our inspectors did not find these problems in
this inspection.
Recommendations
We offer no specific recommendations for this indicator.
10. Minor deficiencies occurred in case 23 and twice in case 22.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
16 Cycle 6 Medical Inspection Report
Compliance Testing Results
Table 6. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most
recent chronic care visit within the health care guideline’s maximum
allowable interval or within the ordered time frame, whichever is 23 2 0 92%
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 patient seen by the clinician within the required time frame? 20 5 0 80%
(1.002) *
Clinical appointments: Did a registered nurse review the patient’s
request for service the same day it was received? (1.003) * 30 0 0 100%
Clinical appointments: Did the registered nurse complete a face-to-
face visit within one business day after the CDCR Form 7362 was 30 0 0 100%
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
maximum allowable time or the ordered time frame, whichever is the 13 2 15 87%
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 8 0 22 100%
frame specified? (1.006) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment within the required time 19 2 4 90%
frame? (1.007) *
Specialty service follow-up appointments: Did the clinician follow-up
visits occur within required time frames? (1.008) * ,† 23 5 2 82%
Clinical appointments: Do patients have a standardized process to
obtain and submit health care services request forms? (1.101) 6 0 0 100%
Overall percentage (MIT 1): 92%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care
physician follow-up visits following specialty services. As a result, we tested MIT 1.008 only for high-
priority specialty services or when staff ordered follow-ups. The OIG continued to test the clinical
appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 17
Table 7. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the N/A N/A N/A N/A
required time frame? (12.003) *
For patients received from a county jail: Did the patient receive a
history and physical by a primary care provider within seven calendar N/A N/A N/A N/A
days? (12.004) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time N/A N/A N/A N/A
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior to
4/2019): Did the primary care provider complete the Subjective, Objective,
9 1 0 90%
Assessment, and Plan notes on the patient at the minimum intervals
required for the type of facility where the patient was treated? (13.003) *
,†
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 15 0 0 100%
Request for Service? (14.001) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 9 1 5 90%
(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 N/A N/A N/A N/A
Request for Service? (14.004) *
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary care N/A N/A N/A N/A
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 15 0 0 100%
Request for Service? (14.007) *
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 3 1 11 75%
(14.009) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still had
state-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
18 Cycle 6 Medical Inspection Report
Diagnostic Services
Overall
Rating In this indicator, OIG inspectors evaluated the institution’s ability
Adequate
to timely complete radiology, laboratory, and pathology tests. Our
inspectors determined whether the institution properly retrieved the
Case Review resultant reports and whether providers reviewed the results correctly.
Rating In addition, in Cycle 6, we examined the institution’s ability to timely
Adequate complete and review stat (immediate) laboratory tests.
Compliance
Results Overview
Score
Inadequate
VSP performed well in test completion with only a few opportunities
(63%)
for improvement noted in this inspection. For example, nurses did not
communicate stat results to providers timely, and providers often failed
to sign test results timely or send results letters to their patients. These
errors were usually not clinically significant; therefore, the OIG rated
this indicator adequate.
Case Review Results
Our clinicians reviewed 181 diagnostic events and identified
11 opportunities for improvement, all of which were minor.11 Of the
11 opportunities for improvement, only one was due to a delay in
diagnostic testing. Ten other opportunities for improvement were related
to health information management.
Test Completion
As in Cycle 5, the institution continued its excellent performance
completing laboratory (MIT 2.004, 100%) and radiology (MIT 2.001, 100%)
services within required time frames. Case review testing also showed
excellent performance, as our clinicians identified only one delay:
• In case 22, the provider ordered a blood test to be performed on a
specific date; however, the diagnostics team drew the laboratory
test two days late. The delay was not clinically significant and did
not affect the patient’s care.
VSP had trouble processing stat laboratory tests on time
(MIT 2.007, 60%). When the nurses received these results, they often
failed to notify the provider timely (MIT 2.008, 20%). Case reviewers
evaluated three cases with stat laboratory events and did not note
any deficiencies.12
Health Information
VSP staff retrieved laboratory and diagnostic test reports promptly
and sent them to the providers for review. However, compliance
11. We noted instances in cases 1, 16, 18, 20, 21, twice in 22, and four times in 11.
12. Stat laboratory events were observed in cases 11, 21, and 22.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 19
testing showed providers often did not sign the radiology reports
(MIT 2.002, 60%) or laboratory reports (MIT 2.005, 70%) on time, nor
send letters notifying patients of their results timely. In case review
testing, our clinicians also found that providers did not always sign the
laboratory reports or send patient notifications timely. We found five
occurrences in which the provider did not endorse the reports on time.
This occurred in cases 20, 22, and the following cases:
• In case 16, the provider did not sign the laboratory results.
• In case 18, the provider waited six days after notification to sign
a test result.
• In case 21, the provider waited 12 days after notification to sign a
test result.
Upon further analysis, our clinicians determined these errors
were not clinically significant. In each of the examples listed, the
providers reviewed the laboratory tests with the patient at subsequent
appointments and made appropriate clinical decisions.
Compliance testing found that the institution retrieved pathology
reports timely (MIT 2.010, 90%) and that VSP providers signed the
reports on time (MIT 2.011, 90%). However, providers did not send results
letters to patients within the required time frames (MIT 2.012, 0%).
When our clinicians analyzed this finding further, they confirmed that
while the VSP providers failed to send results letters to their patients,
providers discussed the results with their patients at subsequent
appointments. Therefore, the pathology report processing errors were
not clinically significant.
Clinician On‑Site Inspection
During our on-site inspection, we interviewed VSP’s leaders and staff
regarding our review findings. In response, all interviewed providers
reported excellent laboratory and radiology ancillary services at VSP.
They also reported diagnostic tests were completed on time. Laboratory
staff reported that they tracked all tests from the time of the order until
the time the providers reviewed the results, and if results were returned
from an outside laboratory or hospital, staff scanned the results into
the EHRS and routed them to the providers. The chief physician and
surgeon (CP&S) explained that he regularly monitored all VSP providers’
electronic inboxes to ensure they were reviewing results.
Recommendations
The CME should audit and address providers’ late reviews of
diagnostic reports.
The CNE should audit stat laboratory results to encourage nurses to
timely notify providers of the stat results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
20 Cycle 6 Medical Inspection Report
Compliance Testing Results
Table 8. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
specified in the health care provider’s order? (2.001) * 10 0 0 100%
Radiology: Did the ordering health care provider review and endorse
the radiology report within specified time frames? (2.002) * 6 4 0 60%
Radiology: Did the ordering health care provider communicate the
results of the radiology study to the patient within specified time 7 3 0 70%
frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
specified in the health care provider’s order? (2.004) * 10 0 0 100%
Laboratory: Did the health care provider review and endorse the
laboratory report within specified time frames? (2.005) * 7 3 0 70%
Laboratory: Did the health care provider communicate the results of
the laboratory test to the patient within specified time frames? (2.006) 0 10 0 0
Laboratory: Did the institution collect the STAT laboratory test and
receive the results within the required time frames? (2.007) * 6 4 0 60%
Laboratory: Did the nursing staff notify the health care provider within
one (1) hour from receiving the STAT laboratory results? (2.008) * 2 8 0 20%
Laboratory: Did the health care provider endorse the STAT laboratory
results within the required time frames? (2.009) 10 0 0 100%
Pathology: Did the institution receive the final pathology report within
the required time frames? (2.010) * 9 1 0 90%
Pathology: Did the health care provider review and endorse the
pathology report within specified time frames? (2.011) * 9 1 0 90%
Pathology: Did the health care provider communicate the results
of the pathology study to the patient within specified time frames? 0 10 0 0
(2.012)
Overall percentage (MIT 2): 63%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 21
Emergency Services
Overall
In this indicator, OIG clinicians evaluated the quality of emergency Rating
Adequate
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 Case Review
the emergency medical response, cardiopulmonary resuscitation (CPR) Rating
quality, TTA care, provider performance, and nursing performance. Adequate
Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) ability to identify problems with its emergency Compliance
services. The OIG assessed the institution’s emergency services Score
through case review only; we did not perform compliance testing for (N/A)
this indicator.
Results Overview
VSP provided adequate emergency care. Staff gave prompt care for
patients who overdosed on narcotics. VSP almost always responded
timely and performed life-saving measures for patients requiring urgent
or emergent care. However, staff sometimes had difficulty recognizing
the signs and symptoms of stroke during this inspection, and the
institution’s nurses could improve their accuracy when recording their
emergency care. Overall, the institution provided sufficient emergency
services, resulting in an adequate rating for this indicator.
Case Review Results
Our clinicians reviewed urgent and emergent events and found
34 opportunities for improvement, three of which were significant.13
Emergency Medical Response
Our clinicians reviewed 40 emergency medical events that required
responses from first medical responders. VSP staff responded promptly
to emergencies throughout the institution; staff gave first aid and began
resuscitation promptly. However, we identified deficiencies in the
following two cases:
• In case 1, the patient complained of general weakness and
dizziness. The first medical responders noted the patient had
slurred speech and numbness of his left arm. The patient
reported he had a history of silent stroke. The nurses did not
recognize the signs and symptoms of a possible stroke, did not
call 9-1-1 immediately, and did not contact a provider until more
than 30 minutes later. This was a significant delay because stroke
patients require immediate, time-sensitive treatment. Although
ultimately the patient did not have a stroke, the failure to follow
clinical protocol was significant.
13. Urgent and emergent events were noted in cases 1, 2, 3, 4, 6, 7, 8, 9, 10, 15, 21, 22, and 23;
significant opportunities for improvement occurred in cases 1, 3, and 23.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
22 Cycle 6 Medical Inspection Report
• In case 3, the patient, who had recently undergone open heart
surgery, was taken to the TTA for recurrent chest pain. The
TTA nurse should have started the nursing chest pain protocol.
This error resulted in a treatment delay of more than 30 minutes.
Although the patient did not have a heart attack, there was a
failure to follow chest pain protocol.
Case reviewers also found nursing documentation errors, such as
inaccurate emergency time lines and missing vital signs. These errors did
not significantly affect the quality of emergency care.
Cardiopulmonary Resuscitation (CPR) Quality
The OIG clinicians reviewed three cases in which staff performed CPR.
In all three cases, custody and medical staff worked collaboratively to
provide quality care.14 In one of the three cases, custody officers started
CPR. Patients overdosed on opioids in two of the three cases, and nurses
promptly administered Narcan (an opioid antidote). However, there
were inaccuracies in the documentation of emergency time lines and
medication administration.
Provider Performance
VSP providers performed well for most patients in urgent or emergent
situations. Providers made accurate assessments and sound triage
decisions. Nonetheless, our case review clinicians found an opportunity
for improvement in the following example:
• In case 2, the patient developed high blood pressure associated
with left arm numbness, weakness, and pain. The TTA provider
did not consider the possibility of stroke. The patient was sent
to a community hospital immediately for high blood pressure.
Although the patient did not have a stroke, the provider’s failure
to consider the possibility of a stroke was clinically significant.
Nursing Performance
Our clinicians found occasional problems with assessments and
interventions in several cases and the following examples:15
• In case 21, the patient went to the TTA for weakness and
dizziness. The TTA nurse administered anti-nausea medication,
but failed to document patient reassessment. Although there was
no adverse outcome, the failure to follow the nursing standard of
care was significant.
• In case 22, the patient went to the TTA on two occasions for
right foot pain. Two different TTA nurses did not assess the
patient’s foot. Although the errors did not affect the outcome for
14. CPR was performed in cases 6, 7, and 8.
15. Nursing performance: cases 1, 3, 21, 22, and 23.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 23
this patient, the failure to assess the patient’s primary complaint
fell below the standard of nursing care.
• Also, in case 22, the patient had chest pain. The nurse did not
follow the provider’s orders of frequent monitoring of vital signs
and neurological status checks. The TTA nurse also did not
follow the order to administer intravenous (IV) fluids. Although
these errors did not affect the outcome for this patient, the
failure to follow orders is a serious lapse in nursing standards.
• In case 23, the medication nurse informed the TTA nurse that
the patient complained of abdominal pain. The TTA nurse
only advised the patient to submit a sick call request without
examining the patient’s abdomen. The error exposed the patient
to severe risk of harm. The patient collapsed the next day and
required hospitalization and surgical consultation.
Nursing Documentation
VSP nurses did not always document their care correctly. We identified
several areas to improve documentation, as follows:
• In cases 6, 21, 22, and 23, the nurses failed to record vital signs.
• In cases 1, 7, 9, 22, and 23, the nurses documented incorrect time
lines of emergency care.
• In cases 4, 6, and 7, the nurses did not accurately document the
administration of a medication.
Emergency Medical Response Review Committee (EMRRC)
The institution’s EMRRC met monthly to review emergency response
cases. The EMRRC performed well and correctly identified the same
quality issues that we identified.
Clinician On‑Site Inspection
The TTA is located in a central medical building at the institution along
with numerous other medical services. The TTA maintained two beds
and one additional overflow bed in an adjacent room. Two emergency
transport vehicles were available for emergency response throughout
the institution. According to VSP staff, they respond to an average of
eight urgent or emergent situations daily. Nurse managers reported that
they adequately staffed the TTA, reviewed staff members’ emergency
responses, and provided training to improve performance. The nurse
instructor reported that the most recent emergency drill scenario
centered on a stroke patient.
Recommendations
We offer no specific recommendations for this indicator.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
24 Cycle 6 Medical Inspection Report
Health Information Management
Overall
Rating In this indicator, OIG inspectors evaluated the flow of health
Adequate
information, a crucial link in high-quality medical care delivery. Our
inspectors examined whether the institution retrieved and scanned
Case Review critical health information (progress notes, diagnostic reports, specialist
Rating reports, and hospital-discharge reports) into the medical record in a
Adequate timely manner. Our inspectors also tested whether clinicians adequately
reviewed and endorsed those reports. In addition, our inspectors checked
Compliance if staff labeled and organized documents in the medical record correctly.
Score
Adequate
Results Overview
(76%)
VSP performed capably with health information management.
Hospital discharge reports were retrieved and endorsed timely.
Although compliance testing showed good performance for specialty
report handling, case review clinicians identified opportunities for
improvement. Nurses did not consistently notify providers of stat results
timely; however, the providers acted upon the results. Staff duplicated
and mislabeled documents in the EHRS. Despite these errors, case
reviewers found that these issues were rarely clinically significant.
Overall, these factors resulted in an adequate rating for this indicator.
Case Review Results
The OIG clinicians reviewed 1,094 events and found 51 opportunities for
improvement related to health information management, of which only
three were significant.16
Hospital Discharge Reports
VSP staff usually retrieved and scanned hospital and discharge records
timely (MIT 4.003, 95%). The hospital discharge reports contained key
elements and were reviewed by the provider timely (MIT 4.005. 80%).
In case review analysis, our clinicians identified problems retrieving
physician discharge summaries in cases 3, 28, and in the following case:
• In case 23, the patient had a lymph node biopsy in the hospital.
The provider recognized the biopsy report was unavailable and
requested the result several times. VSP staff did not retrieve
the pathology report until one month after the provider’s initial
request. Although the biopsy result was benign, the retrieval
was delayed.
In the above three cases, the delays were not clinically significant.
Providers also reviewed and signed the summaries late in cases 3, 22, and
23. Although the providers signed the reports late, they were aware of the
recommendations and made appropriate medical decisions. Please
16. Opportunities for improvement were noted in cases 1, 2, 3, 7, 8, 9, 10, 11, 12, 14, 15, 16, 18,
19, 20, 21, 22, 23, 25, 26, 27, and 28; and were significant in cases 23 and 27.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 25
refer to the Transfers indicator for additional details regarding hospital
discharge reports.
Specialty Reports
In compliance testing, VSP scored well with specialty report retrieval
(MIT 4.002, 90%) and obtaining provider signatures for high-priority
and routine-priority specialty reports (MIT 14.002, 93%, and
MIT 14.008, 80%). Despite these high scores, our case reviewers found
that VSP staff had difficulty retrieving, scanning, and signing specialty
reports. Of the 51 opportunities for improvements case reviewers found
in this indicator, 28 were related to specialty report processing.17
The following specialty report handling errors illustrate how VSP’s
specialty report retrieval system affected patient care:
• In case 27, the medically complex patient had two different
cancers under the care of four different specialists. One
specialist requested imaging tests to care for the patient
properly. VSP staff did not to forward the results of the requested
imaging tests to the specialist. This error contributed to a delay
in cancer treatment because the specialist could not make proper
treatment decisions without the test results.
• Also, in case 27, on a different occasion, VSP staff overlooked
retrieving a consultation report from the medical oncologist.
This error also contributed to a six-month delay in prostate
cancer treatment.
For additional details regarding VSP’s specialty report processing, please
refer to the Specialty Services indicator.
Diagnostic Reports
Overall, VSP performed adequately with diagnostic reports, apart
from notifying providers of stat laboratory reports. Please refer to the
Diagnostic Services indicator for a detailed discussion of these issues.
Compliance testing showed nurses often did not notify the ordering
provider promptly after the stat result became available for review
(MIT 2.008, 20%).
Compliance testing found that the providers usually reviewed and signed
pathology reports timely (MIT 2.011, 90%); however, the providers did not
send letters to their patients to notify them of the results (MIT 2.012, 0%).
These errors were not clinically significant because VSP providers
mitigated the errors by discussing the diagnostic results with their
patients at subsequent clinic appointments.
17. Delayed retrieval or no retrieval occurred in cases 3, 9, 11, 18, 23, 25, 26, and 27; and
either late or no endorsement was noted in cases 7, 9, 10, 12, 15, 19, 21, 22, 23, 25, 26, and 27.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
26 Cycle 6 Medical Inspection Report
Urgent and Emergent Records
Frequently, VSP nurses did not correctly record their emergency care.
Providers recorded their emergency care sufficiently, including their
off-site telephone encounters. Although nurses could improve their
documentation in this area, the problems were not clinically significant.
Please refer to the Emergency Services indicator for additional
information regarding emergency care documentation.
Scanning Performance
Although VSP generally scanned documents timely, our inspectors
found numerous errors in the scanning process. Compliance testing
showed that these errors occurred often (MIT 4.004, 21%). Case review
testing identified the most common errors were duplicate and mislabeled
documents, though none were clinically significant.18
Clinician On‑Site Inspection
At the on-site inspection, our case reviewers met with VSP’s medical
managers, health information management supervisors, providers,
nurses, and ancillary staff. The CME acknowledged that the institution
had difficulty retrieving specialty reports and produced a tracking log of
the specialty reports discussed in the daily provider meetings. The health
records supervisor reported it was difficult obtaining specific specialty
reports from the contracted speech therapist, so VSP contacted the
vendor multiple times and escalated the issue to the contract department
of CCHCS headquarters. According to medical staff, once VSP began
using a different specialty vendor, the problems were resolved.
Recommendations
The chief medical executive (CME) and the chief physician and surgeon
(CP&S) should improve the monitoring of provider care to ensure the
providers are reviewing records thoroughly and documenting all their
medical decisions.
The CME and the chief nursing executive (CNE) should regularly
perform audits of patients returning from off-site hospitals to improve
staff’s retrieval of physician discharge summaries and to encourage
providers and nurses to review discharge records thoroughly.
The CME should audit and address providers’ late reviews of
diagnostic reports.
18. Duplicate documents were found in cases 2, 11, 14, 22, 23, and 27; and mislabeled
documents in cases 1, 9, 11, 16, and 18.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 27
Compliance Testing Results
Table 9. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s
electronic health record within three calendar days of the encounter 19 1 10 95%
date? (4.001)
Are specialty documents scanned into the patient’s electronic health
18 2 10 90%
record within five calendar days of the encounter date? (4.002) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of 19 1 5 95%
hospital discharge? (4.003) *
During the inspection, were medical records properly scanned,
5 19 0 21%
labeled, and included in the correct patients’ files? (4.004) *
For patients discharged from a community hospital: Did the
preliminary or final hospital discharge report include key elements
20 5 0 80%
and did a provider review the report within five calendar days of
discharge? (4.005) *
Overall percentage (MIT 4): 76%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
28 Cycle 6 Medical Inspection Report
Table 10. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Laboratory: Did the nursing staff notify the health care provider within
2 8 0 20%
one (1) hour from receiving the STAT laboratory results? (2.008) *
Pathology: Did the health care provider review and endorse the
9 1 0 90%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results of the
0 10 0 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 14 1 0 93%
frame? (14.002) *
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required N/A N/A N/A N/A
time frame? (14.005) *
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required 12 3 0 80%
time frame? (14.008) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 29
Health Care Environment
Overall
In this indicator, OIG compliance inspectors tested the clinics’ waiting Rating
areas, infection control, sanitation procedures, medical supplies, Inadequate
equipment management, and examination rooms. Inspectors also tested
the clinics’ ability to maintain auditory and visual privacy for clinical Case Review
encounters. Compliance inspectors asked the institution’s health care Rating
administrators to comment on their facility’s infrastructure and its (N/A)
ability to support health care operations. The OIG rated this indicator
solely on the compliance score, using the same scoring thresholds as in Compliance
the Cycle 4 and Cycle 5 medical inspections. Our case review clinicians Score
Inadequate
typically do not rate this indicator.
(69%)
Compliance Testing Results
For this indicator, VSP’s performance declined compared with its
performance in Cycle 5. Waiting areas were adequate, core medical
equipment was available, and proper sanitation and sterilization
procedures were followed. However, improvement was needed in other
aspects of VSP’s health care environment. Some examination rooms
lacked enough space for examination and lacked visual privacy. In a few
clinics, our compliance inspectors found improperly labeled and expired
medical supplies. Emergency medical response bags (EMRBs) were not
properly sealed or inventoried. Medical supply storage areas located
outside the medical clinics did not store medical supplies adequately.
Lastly, VSP staff did not regularly wash their hands when examining
their patients or when applying gloves. These factors resulted in a rating
of inadequate.
Outdoor Waiting Areas
Our compliance
inspectors examined
outdoor patient waiting
areas. Health care
custody staff reported
that the existing waiting
areas (Photo 1, left) had
enough seating capacity,
ample protection from
inclement weather, and
an operational misting
system for use during
extreme heat conditions.
Photo 1. Shaded outdoor waiting area with a mist cooling system
(photographed on 4/23/19).
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
30 Cycle 6 Medical Inspection Report
Indoor Waiting Areas
Inside the medical clinics,
there was enough seating
capacity for patients waiting for
their appointments (Photo 2,
left). In addition to the main
waiting room, there were three
additional adjacent rooms for
patient overflow. Although there
were several patients standing
in the main waiting room,
the patients explained they
preferred standing in the main
waiting room instead of sitting
in the adjacent waiting rooms.
Photo 2. Indoor waiting area with open seating (photographed on 4/22/19).
Clinic Environment
All nine applicable clinics had
environments conducive for medical
care. Our inspectors found reasonable
auditory privacy, appropriate
waiting areas, good wheelchair
accessibility, and ample workspace
(MIT 5.109, 100%).
Of the nine examination rooms
observed, five had sufficient
space, configuration, supplies,
and equipment, permitting VSP
clinicians to perform proper clinical
examinations. The remaining four
examination rooms had one or more
of the following opportunities for
improvement: insufficient space;
examination table placement
preventing patients from lying down
fully (Photo 3, right); lack of visual Photo 3. Examination table with insufficient space for a patient to lie down
(photographed on 4/25/19).
privacy, or unsecured confidential
medical records (MIT 5.110, 56%).
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 31
Clinic Supplies
Six of the nine observed clinics
followed adequate medical supply
storage and management protocols. In
three other clinics, inspectors found
improperly labeled medical supplies,
and one of the three clinics had expired
medical supplies (Photo 4, right)
(MIT 5.107, 67%).
All nine clinics met requirements for
essential core medical equipment and
supplies (MIT 5.108, 100%).
Our inspectors examined seven
EMRBs to determine if they contained
all essential items. They checked if
staff inspected the bags daily and
inventoried them monthly. Only
one of the seven EMRBs passed
the compliance test. For the other
Photo 4. Expired medical supplies dated December 2018
six EMRBs, staff failed to seal the (photographed on 4/22/19).
EMRBs’ compartments or ensure they
were intact, or had not inventoried
the EMRBs in the previous 30 days
(MIT 5.111, 14%).
Medical Supply Management
None of the medical supply storage
areas located outside the medical clinics
(e.g., warehouse, Conex containers, etc.)
stored medical supplies adequately. Our
inspectors also found medical supplies
with torn sterile packaging (Photo 5, left)
(MIT 5.106, 0%).
According to the CEO, the institution
was in the process of transferring
bulk items from the Conex containers
to the warehouse. Furthermore,
health care managers expressed no
concerns about the medical supply
chain or their communication with the
Photo 5. Torn sterile packaging (photographed on 4/22/19). main warehouse.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
32 Cycle 6 Medical Inspection Report
Infection Control and Sanitation
Staff appropriately cleaned, sanitized, and disinfected all nine clinics
(MIT 5.101, 100%). Staff in eight of nine clinics properly sterilized or
disinfected medical equipment. In the other clinic, when describing their
daily protocol, staff did not discuss disinfecting the examination table
prior to their shift (MIT 5.102, 89%). Our inspectors found operating
sinks and hand hygiene supplies in the examination rooms of all nine
clinics (MIT 5.103, 100%).
Our inspectors observed patient encounters in eight clinics and found
that VSP staff followed good hand hygiene practices in three clinics. In
five other clinics, VSP staff failed to wash their hands before or after
examining their patients or before applying gloves (MIT 5.104, 38%).
Health care staff in all clinics followed proper protocols to mitigate
exposure to blood-borne pathogens and contaminated waste
(MIT 5.105, 100%).
Physical Infrastructure
At the time of the compliance inspection, VSP was renovating and
adding clinic space to four clinics. These projects began in 2015, and
management estimated they would be complete by winter 2020. During
our interview, VSP’s health care management and the CEO explained
that staff were caring for yard clinic patients in the infirmary clinic
while the yard clinic was under renovation. The CEO was concerned that
his staff was rendering too many services (including yard clinic, TTA,
specialty clinic, and physical therapy) in the infirmary clinic but did not
believe the extra foot traffic had compromised patient care (MIT 5.999).
Recommendations
The CNE and nursing supervisors should improve the inventory process
to ensure EMRBs are properly maintained.
Medical staff should be retrained and reminded to follow universal
hand hygiene precautions. Implementing random spot checks may help
with compliance.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 33
Compliance Testing Results
Table 11. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately
9 0 0 100%
disinfected, cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable
invasive and noninvasive medical equipment is properly sterilized or 8 1 0 89%
disinfected as warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks
9 0 0 100%
and sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal
3 5 1 38%
hand hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to
9 0 0 100%
blood-borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the
medical supply management process adequately support the needs 0 1 0 0
of the medical health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for
6 3 0 67%
managing and storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have
9 0 0 100%
essential core medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas
9 0 0 100%
conducive to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms
5 4 0 56%
conducive to providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency
crash carts inspected and inventoried within required time frames, 1 6 2 14%
and do they contain essential items? (5.111)
Does the institution’s health care management believe that all clinical This is a nonscored test. Please
areas have physical plant infrastructures that are sufficient to provide see the indicator for discussion
adequate health care services? (5.999) of this test.
Overall percentage (MIT 5): 69%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
34 Cycle 6 Medical Inspection Report
Transfers
Overall
Rating In this indicator, OIG inspectors examined the transfer process for
Inadequate those patients who transferred into the institution, as well as for those
who transferred to other institutions. For newly arrived patients, our
Case Review inspectors assessed the quality of health screenings and the continuity
Rating of provider appointments, specialist referrals, diagnostic tests, and
Inadequate medications. For patients who transferred out of the institution,
inspectors checked whether staff reviewed patient medical records and
Compliance determined the patient’s need for medical holds. They also assessed if
Score staff transferred patients with their medical equipment and gave correct
Inadequate
medications before patients left. In addition, our inspectors evaluated the
(66%) ability of staff to communicate vital health transfer information, such as
preexisting health conditions, pending appointments, tests, and specialty
referrals; and inspectors confirmed if staff sent complete medication
transfer packages to the receiving institution. For patients who returned
from off-site hospitals or emergency rooms, inspectors reviewed
whether staff appropriately implemented the recommended treatment
plans, administered necessary medications, and scheduled appropriate
follow-up appointments.
Results Overview
VSP revealed multiple opportunities for improvement in this indicator.
For patients returning from an off-site hospital, our inspectors identified
several important issues, including: lack of medication continuity,
incorrect retrieval of physician discharge summaries, lack of careful
review of hospital discharge records, and delayed posthospital follow-up
appointments. For patients transferring into the institution we found
incomplete initial nurse health screenings, intermittently delayed initial
intake provider appointments, medication continuity lapses for chronic
care patients, and delayed specialty referrals due to the transfer. VSP
performed adequately for patients transferring to other institutions.
These factors resulted in an inadequate rating for this indicator.
Case Review Results
The OIG clinicians reviewed cases in which patients transferred into or
out of the institution, or returned from an off-site hospital or emergency
room. Case reviewers identified 28 opportunities for improvement in
VSP’s hospital return processes.
Transfers In
Compliance testing showed reception and receiving (R&R) nurses scored
poorly when performing the initial health screening (MIT 6.001, 8%).
Analysis of the compliance data showed that while the nurses completed
the screening forms on time, they rarely complete the forms thoroughly.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 35
Our case review clinicians found nine deficiencies19 in this process
related to insufficient nursing assessment and intervention in the
following four cases:
• In case 58, the R&R nurses did not obtain a full set of vital signs
as part of the initial health screening. The OHU nurse obtained
vital signs upon admission. This minor error did not affect the
patient’s care.
• In case 22, the patient complained of pain upon arrival at VSP.
The R&R nurse did not administer the patient’s prescribed
pain medication.
• In cases 31 and 32, the R&R nurses did not recognize that
diabetes was a risk factor for valley fever.
Compliance testing showed poor medication continuity for newly arrived
patients (MIT 6.003, 68%). Case review testing also found delays in
medication delivery; however, our clinicians determined most of these
delays were not clinically significant.
VSP generally provided good access to primary care providers when
patients transferred into the institution (MIT 1.002, 80%); however, only
two of the five high-risk patients (40%) saw their provider timely. Case
review testing also found room for improvement in this area:
• In case 1, the patient was receiving cancer treatment when he
transferred to VSP. This high-risk patient was not seen by the
primary care provider within seven days.
Compliance testing showed VSP had difficulty scheduling timely
specialty appointments for patients who transferred into the institution
with preapproved specialty referrals (MIT 14.010, 65%).
Transfers Out
VSP’s transfer-out process was adequate. Compliance testing found that
most transfer medication packets were complete (MIT 6.101, 86%). While
our clinicians found the performance adequate in this area, we found
opportunities for improvement:
• In case 33, the nurse did not document a pending esophago-
gastroduodenoscopy (EGD)20 appointment in the transfer
information notes. Although there was no delay in care, this did
not follow policy.
• In case 34, the nurse did not obtain the diabetic patient’s
morning blood sugar level before transferring him out, resulting
in the patient’s exposure to significant risk of harm.
• In cases 22, 33, and 34, the R&R nurses did not check patients’
vital signs before the patients transferred out of VSP.
19. Cases 1, 22, 31, 32, and 58.
20. The esophagogastroduodenoscopy (EGD) is a procedure in which the physician
inserts a camera scope into the mouth and advances to the small intestine to examine the
esophagus, stomach, and the first portion of the small intestine.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
36 Cycle 6 Medical Inspection Report
Hospitalizations
Patients returning from an off-site hospitalization or an emergency
room may have experienced severe illness or injury. These patients often
have complex medical issues and are especially susceptible to lapses in
care. Even seemingly small lapses in care for these patients can result in
serious consequences.
Compliance testing found an acceptable continuity of hospital-
recommended medications (MIT 7.003, 75%) and good provider follow-
ups after patients returned from a community hospital (MIT 1.007, 90%).
Case reviewers found room for improvement with VSP’s hospital-
return performance. Our clinicians reviewed 26 hospital or emergency
department returns and identified 15 opportunities for improvement,
four of which were significant.21 In the case reviews, staff did not always
assess their patients, review hospital records, or intervene correctly:
• In case 1, the nurse and the provider did not follow hospital
discharge medication recommendations to stop a blood pressure
medication. As a result, the patient had low blood pressure.
• In case 2, the nurse incorrectly entered a five-day provider
follow-up order. The nurse transposed the start and end dates.
• In case 3, the provider did not order daily aspirin and did not
request follow-up with the specialist as recommended by
the hospitalist. This case is also discussed in the Specialized
Medical Housing indicator.
• In case 22, the nurse did not order the provider hospital follow-
up within five days as required by policy.
Compliance testing found that staff retrieved discharge documents
timely (MIT 4.003, 95%) and retrieved physician discharge summaries
80 percent of the time (MIT 4.005). Case review testing confirmed
compliance results.22 Providers also reviewed and signed the summaries
late in cases 3, 22, and 23. Please refer to the Health Information
Management indicator for additional details.
Clinician On‑Site Inspection
Our clinicians met with the nurse managers at VSP to discuss some
of the case review findings. They agreed with the opportunities for
improvement we identified, and indicated they would provide additional
education and training for their staff.
Compliance On‑Site Inspection
Our compliance inspectors examined the contents of the transfer packets
for all patients transferring out of the institution. In one transfer packet,
21. These occurred in cases 1, 2, 3, 21, 22, 23, and 28, with significant deficiencies noted in
cases 1, 3, 22, and 23.
22. Retrieved discharge documents were late in cases 3, 23, and 28.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 37
inspectors found one expired medication. VSP staff immediately removed
the expired medication. In addition, our inspectors checked patients who
were transferring with durable medical equipment and found all patients
possessed this equipment at the time of transfer.
Recommendations
The CNE should monitor the performance of R&R nurses to ensure
that complete nursing assessments and proper interventions for newly
arrived patients occur. Implementing an electronic alert to encourage the
completion of EHRS electronic nursing assessment forms may help.
Compliance Testing Results
Table 12. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: Did nursing staff complete the initial health screening and
2 23 0 8%
answer all screening questions within the required time frame?
(6.001) *
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
disposition section of the initial health screening form; refer the
25 0 0 100%
patient to the TTA if TB signs and symptoms were present; and
sign and date the form on the same day staff completed the health
screening? (6.002)
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
13 6 6 68%
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the corresponding 6 1 2 86%
transfer packet required documents? (6.101) *
Overall percentage (MIT 6): 66%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
38 Cycle 6 Medical Inspection Report
Table 13. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 20 5 0 80%
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 19 2 4 90%
within the required time frame? (1.007) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of hospital 19 1 5 95%
discharge? (4.003) *
For patients discharged from a community hospital: Did the preliminary
or final hospital discharge report include key elements and did a
20 5 0 80%
provider review the report within five calendar days of discharge?
(4.005) *
Upon the patient’s discharge from a community hospital: Were all
ordered medications administered, made available, or delivered to the 15 5 5 75%
patient within required time frames? (7.003) *
Upon the patient’s transfer from one housing unit to another: Were
23 2 0 92%
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 N/A N/A N/A N/A
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
13 7 0 65%
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 39
Medication Management
Overall
In this indicator, OIG inspectors evaluated the institution’s ability to Rating
administer prescription medications on time and without interruption. Inadequate
The inspectors examined this process from the time a provider
prescribed medication until the nurse administered the medication to Case Review
the patient. When rating this indicator, the OIG strongly considered Rating
the compliance test results, which tested medication processes to a Inadequate
much greater degree than case review testing. In addition to examining
medication administration, our compliance inspectors also tested many Compliance
other processes, including medication handling, storage, error reporting, Score
Inadequate
and other pharmacy processes.
(70%)
Results Overview
As in Cycle 5, VSP continued to struggle in this indicator. For Cycle 6,
our inspectors identified the following medication processes that
showed significant room for improvement: the timely provision of newly
prescribed medications, the continuity of chronic care medications,
medications for patients transferring into VSP, and the monitoring
of patients taking TB medications. On the other hand, we found
the following VSP medication processes adequate: the continuity of
medications for patients admitted to the OHU, the transfer of patients to
other institutions with appropriate medications, and the administration
of TB medications. Taking these factors into consideration, along with
compliance testing, the OIG rated this indicator inadequate.
Case Review Results
Our clinicians reviewed 163 events within 49 cases related to medications
and found 34 opportunities for improvement, two of which were
significant.23
New Medication Prescriptions
Our clinicians found that staff occasionally did not administer new
medications at times specified by the prescription. Compliance testing
revealed that patients received their new medications 76 percent of the
time (MIT 7.002). For 19 sampled patients, 13 received their medications
on time. Five patients received their medications between one and
four days late, and for one other patient, nursing staff administered his
medications incorrectly. In case review testing, our clinicians also found
a pattern of new medications administered late in cases 7, 10, 23, 28, and
in the following cases:24
23. Significant deficiencies were noted in cases 16 and 19.
24. Medication was late in cases 1, 7, 23, 28, and the dose was inaccurate in case 10.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
40 Cycle 6 Medical Inspection Report
• In case 1, the patient received two different prostate medications
late. Although these delays were not clinically significant, they
did not follow policy.
• In case 15, the patient had an eye injury, and the provider
prescribed eye drops to treat swelling and infection. The patient
received the eye drops one to two days late. This delay increased
the patient’s risk of infection and eye damage.
• In case 18, the provider ordered medications for acid reflux and
pain. The patient received his medications one and five days late.
These delays were not clinically significant.
• In case 19, the provider prescribed a new medication for the
patient’s acid-damaged esophagus, but the patient never
received the medication. This increased the risk of esophageal
damage, including abdominal pain and ulcers. During the on-
site inspection, the institution did not provide evidence that the
pharmacy dispensed or delivered the medication.
Chronic Medication Continuity
VSP had difficulty ensuring medication continuity for patients with
chronic conditions. Compliance testing showed low compliance in this
area (MIT 7.001, 13%). Case review testing also identified issues with
medication continuity in cases 15, 22, 28, and in the following cases:
• In case 13, the patient did not receive his blood pressure and
diabetes medications for one month. This lapse increased the
patient’s risk of poor diabetes and blood pressure control.
• In case 16, the provider failed to renew the patient’s prescription
for chronic acid reflux. At the on-site inspection, the pharmacist
reported the medication should have shown up in the automated
huddle agenda. However, staff showed the medication was not
listed in the huddle agenda. The institution did not provide
documentation that the nurse notified the physician about the
expired medication.
• In case 17, the provider prescribed the patient nitroglycerin
for ongoing chest pains. When the patient ran out of this
medication, the nurse sent the refill request to the wrong
message pool. As a result, the patient did not get his
nitroglycerin for three weeks.
Hospital Discharge Medications
Compliance testing found sufficient medication continuity for 15 of
20 patients who returned from a community hospital (MIT 7.003, 75%).
Case review testing showed similar performance. Please refer to the
Transfers indicator for additional details.
Specialized Medical Housing Medications
Patients in the OHU usually received their medications on time.
Although compliance testing showed some delays in this area
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 41
(MIT 13.004, 50%), our clinicians found those delays were not clinically
significant because most were fewer than two hours. In case review
testing, clinicians also found minor, nonclinically significant delays. In
the six OHU case reviews, two patients received their medications one to
two days late.25
Transfer Medications
VSP did not adequately ensure medication continuity for patients
transferring into the institution. Compliance testing showed patients
received their prescribed medications timely upon arriving to VSP from
another institution in only 13 of the 19 samples tested (MIT 6.003, 68%).
For patients transferring out of VSP, staff performed well with
medication continuity. Our clinicians did not find any opportunities for
improvement in the cases we reviewed. Compliance testing also showed
good completion of medication transfer packets (MIT 6.101, 86%).
Our compliance testing also showed VSP performed well with
medication continuity for patients transferring from one housing unit
to another (MIT 7.005, 92%). Out of 25 patients sampled, 23 patients
received their medications without interruption when they transferred
from one housing unit to another. For additional details, please refer to
the Transfers indicator.
Medication Administration
Our clinicians found that VSP nurses often administered medications
timely and properly. However, case reviewers identified several types
of nurse medication administration errors in this inspection. The
institution can use the following examples for quality improvement:
• In case 2, the nurse did not review the patient’s medical record
and administered an influenza vaccine twice. Although this did
not impact patient care, this was below the nursing standards
of care.
• In case 10, nurses administered the patient’s antiviral medication
four times a day instead of the prescribed five times a day. This
increased the risk of the patient losing his eyesight due to a viral
infection of the eye. Although this error did not have a clinical
effect, this was below the nursing standards of care.
• In case 22, the nurse did not administer the patient’s chronic
medications on several occasions. The patient missed doses of
his cholesterol, asthma, and diabetes medication. Although these
errors were not clinically significant, this was below the nursing
standards of care.
Compliance testing examined how VSP staff administered and monitored
patients taking tuberculosis (TB) medications and found nurses
correctly administered TB medications as prescribed (MIT 9.001, 100%).
25. Cases 23 and 57.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
42 Cycle 6 Medical Inspection Report
However, nurses routinely failed to monitor these patients correctly
(MIT 9.002, 0%). Monitoring for side effects of TB medications
is important because these medications can be very harmful to a
patient’s liver.
Clinician On‑Site Inspection
OIG clinicians interviewed nurses and observed them during medication
administration. The nurses were familiar with processes for medication
renewals, new prescriptions, transfer medications, and administering
“keep on person” (KOP) medications timely. The medication
nurses attended the clinic huddles and informed the providers of
expiring medications.
Our clinicians also met with pharmacy and nursing staff to discuss
our case review findings. In response, the pharmacist in charge (PIC)
explained that VSP was implementing a “pharmacy correctional clinic”
model, where each clinic will have an Omnicell (automated medication
storage and dispensing cabinet). According to the PIC, this will improve
storage and access to medications, enabling VSP to provide continuous
medication availability, 24 hours per day, seven days per week. With this
implementation, the PIC predicted that VSP will receive a higher rating
in this indicator in Cycle 7.
Compliance Testing Results
Medication Practices and Storage Controls
The institution failed to store and secure narcotic medications correctly
in the seven applicable clinic and medication line locations we tested. In
all seven locations, our inspectors identified one or more of the following
opportunities for improvement: two licensed nurses did not counter-
sign the logbook for narcotics during the inventory count; nurses did
not update the logbook when they administered narcotic medications;
and nurses did not record in the logbook the administration date, time,
patient identification number, and reason for disposal of narcotics
(MIT 7.101, 0%).
VSP appropriately stored and secured nonnarcotic medications in all
eight applicable clinic and medication line locations (MIT 7.102, 100%).
Staff properly protected medications from physical, chemical, and
temperature contamination in seven of the eight clinic and medication
line locations. Staff separated the storage of oral and topical
medications for one location (MIT 7.103, 88%). Staff successfully stored
valid, unexpired medications in six of the eight applicable clinic and
medication line locations. In one clinic, nurses did not label the multiple-
use medication with the date it was opened,26 and in another clinic,
26. On May 2019, the department changed the policy regarding multiple-use medication
labeling to require listing the expiration date instead of the opening date.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 43
nurses generally stored multiple-use refrigerated medication according
to the manufacturers’ guidelines (MIT 7.104, 75%).
Medication nurses exercised proper hand hygiene and contamination
control protocols at four of six locations. In two locations, some nurses
neglected to wash or sanitize their hands before subsequent regloving
(MIT 7.105, 67%).
Medication nurses at three of the six inspected medication line locations
employed appropriate administrative controls and followed protocols
during medication preparation. In two locations, nursing staff did not
explain their process for reconciling new medications received from
the pharmacy with the physician’s order. At another location, nurses
improperly opened the original packages before issuing the medications
to the patients. Inspectors found loose medications in the medication
carts; these medications were contaminated and would require
disposal (MIT 7.106, 50%). Staff in five of six medication preparation
and administration locations demonstrated appropriate administrative
controls and protocols (MIT 7.107, 83%). In one location, a medication
nurse did not appropriately administer medication as ordered by
the provider.
Pharmacy Protocols
VSP’s pharmacy followed general security, organization, and cleanliness
management protocols (MIT 7.108, 100%). The pharmacy properly stored
nonrefrigerated medication (MIT 7.109, 100%). We found one example of
an expired medication in the pharmacy refrigerator (MIT 7.110, 0%).
The PIC correctly accounted for narcotic medications stored in VSP’s
pharmacy (MIT 7.111, 100%). Inspectors examined 14 medication error
reports and found the PIC processed all reports timely (MIT 7.112, 100%).
Nonscored Tests
In addition to testing the institution’s self-reported medication errors,
OIG inspectors also followed up on any significant medication errors
found during compliance testing. We do not score this test; these results
are provided for informational purposes only. We did not find any
applicable medication errors for VSP (MIT 7.998).
In the VSP administration segregation unit, we interviewed the one
applicable patient and determined the patient had access to his rescue
medications (MIT 7.999).
Recommendations
VSP medical leadership should examine and modify the
institution’s medication processes to ensure timely and appropriate
medication administration.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
44 Cycle 6 Medical Inspection Report
Table 14. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required
time frames or did the institution follow departmental policy for refusals or 3 20 2 13%
no-shows? (7.001) *
Did health care staff administer, make available, or deliver new order
19 6 0 76%
prescription 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 15 5 5 75%
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 N/A N/A N/A N/A
delivered to the patient within the required time frames? (7.004) *
Upon the patient’s transfer from one housing unit to another: Were
23 2 0 92%
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 administered or N/A N/A N/A N/A
delivered without interruption? (7.006) *
All clinical and medication line storage areas for narcotic medications: Does
the institution employ strong medication security controls over narcotic 0 7 3 0
medications assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution properly secure and store nonnarcotic medications in the 8 0 2 100%
assigned storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution keep nonnarcotic medication storage locations free of 7 1 2 88%
contamination in the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does
the institution safely store nonnarcotic medications that have yet to expire in 6 2 2 75%
the assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ
and follow hand hygiene contamination control protocols during medication 4 2 4 67%
preparation and medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications 3 3 4 50%
for patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering 5 1 4 83%
medications to patients? (7.107)
Pharmacy: Does the institution employ and follow general security,
organization, and cleanliness management protocols in its main and remote 1 0 0 100%
pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
1 0 0 100%
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
14 0 0 100%
protocols? (7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the This is a nonscored test. Please
OIG find that medication errors were properly identified and reported by the see the indicator for discussion of
institution? (7.998) this test.
Pharmacy: For Information Purposes Only: Do patients in isolation housing This is a nonscored test. Please
units have immediate access to their KOP prescribed rescue inhalers and see the indicator for discussion of
nitroglycerin medications? (7.999) this test.
Overall percentage (MIT 7): 70%
* The OIG clinicians considered these compliance tests along with their case review findings when determining the
quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 45
Table 15. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
13 6 6 68%
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the corresponding 6 1 2 86%
transfer-packet required documents? (6.101) *
Patients prescribed TB medication: Did the institution administer the
8 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 0 8 0 0
the medication? (9.002) *
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 5 5 0 50%
within required time frames? (13.004) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
46 Cycle 6 Medical Inspection Report
Preventive Services
Overall
Rating In this indicator, OIG compliance inspectors tested whether the
Inadequate institution offered or provided cancer screenings, tuberculosis
(TB) screenings, influenza vaccines, and other immunizations.
Case Review If the department designated the institution as high risk for
Rating coccidioidomycosis (valley fever), our inspectors tested the institution’s
(N/A) ability to transfer patients out quickly. The OIG rated this indicator
solely based on the compliance score, using the same scoring thresholds
Compliance as in the Cycle 4 and Cycle 5 medical inspections. Our case review
Score clinicians do not rate this indicator.
Inadequate
(73%) Recommendations
We offer no specific recommendations for this indicator.
Compliance Testing Results
Table 16. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
8 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 0 8 0 0
the medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last
15 10 0 60%
year? (9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 50 through the age of 75: Was the
24 1 0 96%
patient offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the
N/A N/A N/A N/A
patient offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was
N/A N/A N/A N/A
patient offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients?
10 2 13 83%
(9.008)
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): 73%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 47
Nursing Performance
Overall
In this indicator, the OIG clinicians evaluated the quality of care Rating
delivered by the institution’s nurses, including registered nurses (RNs), Adequate
licensed vocational nurses (LVNs), psychiatric technicians (PTs), and
certified nursing assistants (CNAs). Our clinicians evaluated nurses’ Case Review
ability to make timely and appropriate assessments and interventions. Rating
We also evaluated the institution’s nurses’ documentation for accuracy Adequate
and thoroughness. Clinicians reviewed nursing performance in many
clinical settings and processes, including sick call, outpatient care, care Compliance
coordination and management, emergency services, specialized medical Score
housing, hospitalizations, transfers, specialty services, and medication (N/A)
management. The OIG assessed nursing care through case review only
and performed no compliance testing for this indicator.
When summarizing overall nursing performance, our clinicians
understand that nurses perform numerous aspects of medical care. As
such, specific nursing quality issues are discussed in other indicators,
such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Results Overview
VSP nurses provided good nursing care, as noted in Cycle 5. However,
our clinicians identified opportunities for improvement in some several
areas of the nursing process described in the subcategories below.
These nursing process errors did not place patients at significant risk
of harm. Considering all these factors, the OIG clinicians rated this
indicator adequate.
Case Review Results
The OIG clinicians reviewed 284 nursing encounters in 56 cases. Of
the nursing encounters reviewed, 122 were in the outpatient setting.
Case reviewers identified 104 nursing performance opportunities for
improvement, eight of which were significant.27
Nursing Assessment and Intervention
A critical component of nursing care is the quality of nursing
assessment, which includes both subjective (patient interview) and
objective (observation and examination) elements. Another essential
factor for quality nursing care is nursing intervention.
Although VSP nurses made appropriate assessments and interventions,
at times they did not review their patients’ medical records properly and
did not perform thorough assessments. Fortunately, these errors were
minor and did not significantly affect patient care. The following two
deficiencies are examples:
27. Significant deficiencies occurred in cases 1, 3, 16, 19, 22, 23, and 44.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
48 Cycle 6 Medical Inspection Report
• In case 16, the nurse noted on several occasions that the patient
was compliant with all his medications. However, the patient
periodically refused his asthma medication and medicated eye
drops. The nurses did not properly review the patient’s medical
record to identify the refusals and did not counsel the patient
concerning medication compliance.
• In case 19, the patient had a lower-extremity infection. On
multiple occasions, the nurses did not assess the patient’s
affected area appropriately, including assessing the patient’s gait,
pedal pulses, or skin temperature.
VSP nurses did not always intervene appropriately for their patients. The
most commonly identified error was that nurses periodically failed to
address their patients’ symptoms. These oversights occurred in cases 2, 8,
16, 22, 23, 44, 45, and the following case:
• In case 17, the nurses did not inform the provider when the
patient had high blood pressure readings. On another occasion,
the patient submitted a sick call request for severe back and
lower extremity pain, but the nurse did not examine the patient
on the same day. Although these errors did not harm the patient,
they fell below nursing standards of care.
Nursing Documentation
Without proper documentation, health care staff can overlook changes in
a patient’s condition or transmit incomplete or inaccurate information.
Poor documentation increases the risk of lapses in care.
In most areas, VSP nurses recorded their care acceptably. However,
our case reviewers found opportunities for improvement in
emergency services, such as time-line discrepancies and incomplete
documentation.28 These errors were not clinically significant.
Nursing Sick Call
Our clinicians reviewed 83 sick call requests. The clinic nurse saw
an average of eight patients per day, and staff reported no nurse
appointment backlog. VSP nurses usually reviewed sick call requests
the same day they received them and performed timely evaluations
for symptomatic patients. Most nurses followed the appropriate
nursing protocols.
However, clinic nurses intermittently made incomplete evaluations.
Although these errors did not affect the overall care that the patients
received, they were below nursing standards of care. VSP nurse managers
should use the following examples for training purposes:
28. Opportunities for improvement were observed in cases 1, 3, 4, 6, 7, 9, 21, and 23.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 49
• In case 18, the patient complained of severe ear pain, itchiness,
and ankle pain. The nurse did not evaluate the patient’s hearing,
describe the appearance of the patient’s eardrum, nor evaluate
the patient’s gait.
• In case 53, the patient complained of arthritis pain while
walking and difficulty standing up from a sitting position.
The patient did not have pain on the day of the face-to-face
appointment. The nurse did not assess the patient’s gait nor
lower-extremity strength.
Care Coordination
VSP managers assigned one LVN care coordinator to each clinic. The
care coordinators provided education regarding chronic care conditions,
performed tuberculosis (TB) screenings, and issued medical supplies.
Our clinicians did not identify any problems in this area during
this inspection.
Wound Care
Our clinicians did not identify any wound care errors. The nurses
performed wound care consistent with the providers’ orders.
Emergency Services
The nurses responded promptly to medical emergencies. Nurses in the
TTA appropriately assessed and intervened for their patients. However,
nurses demonstrated poor documentation in this area, as detailed in the
Emergency Services indicator.
Transfers
R&R nurses often did not categorize diabetic patients with elevated risk
for valley fever and sometimes did not check vital signs before patients
transferred to another institution. The TTA nurses did not always
properly review or inform the provider of hospital recommendations.
Please refer to the Transfers indicator for further details.
Specialized Medical Housing
The nurses in the OHU made timely and suitable nursing assessments.
The Specialized Medical Housing indicator has additional details.
Specialty Services
VSP nurses provided good care for patients returning from off-site
specialty and telemedicine appointments. Please refer to the Specialty
Services indicator for additional discussion.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
50 Cycle 6 Medical Inspection Report
Medication Management
The nurses administered medications timely and as ordered. The
Medication Management indicator provides further information.
Clinician On‑Site Inspection
We spoke with nurses in several clinical areas, including the TTA,
OHU, R&R, specialty, utilization management, outpatient clinics, and
medication areas. Our clinicians attended a well-coordinated clinic
huddle, where the provider conveyed pertinent information from the
morning provider meeting to the clinic staff. The clinic staff were
familiar with their patients.
The clinicians discussed the case review findings with nurse managers,
who acknowledged the findings and were training the nurses. Nurse
managers reported that they held “town hall” educational meetings. The
CNE was knowledgeable and well-versed regarding nursing issues.
Recommendations
We offer no specific recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 51
Provider Performance
Overall
In this indicator, OIG case review clinicians evaluated the quality of Rating
care the institution’s providers (physicians, physician assistants, and Adequate
nurse practitioners) delivered. Our clinicians assessed the institution’s
providers’ ability to evaluate, diagnose, and manage their patients Case Review
properly. We examined provider performance across several clinical Rating
settings and programs, including sick call, emergency services, Adequate
outpatient care, chronic care, specialty services, intake, transfers,
hospitalizations, and specialized medical housing. The OIG assessed Compliance
provider care through case review only and performed no compliance Score
testing for this indicator. (N/A)
Results Overview
VSP providers usually delivered good patient care and made accurate
assessments and appropriate decisions. At the on-site inspection, the
institution’s providers reported high morale. While provider performance
was rated adequate overall, the OIG physicians found some opportunities
for improvement in several important areas. VSP’s providers often did
not review their patients’ medical records sufficiently and repeatedly
did not document their medical care. Fortunately, these errors were not
widespread and they usually did not result in increased risk of patient
harm. These factors resulted in an adequate rating for this indicator.
Case Review Results
In 25 comprehensive case reviews, our physicians reviewed 225 face-
to-face provider encounters and found one or more provider errors
in 62 encounters. We found a total of 84 provider opportunities for
improvement, 21 of which were significant.
Assessment and Decision‑Making
In most cases, VSP providers made good assessments and decisions,
diagnosed illnesses correctly, made appropriate follow-up appointments,
ordered suitable tests, and referred their patients to the proper
specialists. However, case reviewers identified occasionally questionable
decision-making and found opportunities for improvement in cases 3, 15,
and in the following case:
• In case 10, the provider prescribed an unnecessary blood thinner.
The patient did not need the blood thinner because he had
a biological heart valve. By prescribing the medication, the
provider unnecessarily increased the patient’s risk of bleeding.
• Also, in case 10, the provider misdiagnosed the patient with a
blood clot in the lungs (pulmonary embolism) and incorrectly
continued blood thinner medication. The provider did not order
any of the necessary laboratory or imaging tests before the
diagnosis of pulmonary embolism. This action unnecessarily
increased the patient’s risk of bleeding. While the provider’s
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
52 Cycle 6 Medical Inspection Report
error was significant, the error was internally identified and
corrected by the CP&S before patient harm occurred.
Review of Records
The review of records is a basic and essential component of a provider’s
evaluation. This review is especially important if the patient underwent
recent testing, saw a specialist, or returned from a higher level of care.
Providers also must review records for patients unfamiliar to them.
VSP providers demonstrated many opportunities for improvement in
this area. In fact, 27 of the 82 provider opportunities for improvement
occurred because providers did not sufficiently review their patients’
records. Of the 82 opportunities for improvement, 11 were clinically
significant. Providers had errors in reviewing records for patients
following hospital return, specialty consultations, diabetes care, and
medical procedures.29 The errors affected providers’ diagnoses and
treatments. Examples follow:
• In case 2, the provider did not recognize a new diagnosis of
diabetes on laboratory review. Consequently, the provider
failed to treat the patient’s diabetes for the remainder of the
review period.
• In case 3, the provider did not reconcile the cardiology follow-
up order after hospitalization for heart bypass surgery. As a
result, the patient did not see the cardiologist timely. On site, the
provider agreed that he made the mistake.
• In case 9, the provider reviewed imaging studies showing kidney
hemorrhagic cysts (blood-filled sacs), but did not order the
recommended follow-up studies. Another provider also made the
same error a month later. No subsequent provider addressed the
patient’s kidney cysts in the review period.
• As mentioned previously, in case 10, the provider mistakenly
prescribed a blood thinner. The provider did not review the
echocardiogram30 carefully to identify that the patient had a
biological tissue heart valve and did not need anticoagulation.
Emergency Care
VSP providers appropriately managed patients with urgent or emergent
conditions at the TTA. The providers appropriately examined, diagnosed,
and triaged patients with urgent and emergent conditions. Our clinicians
found only three minor opportunities for improvement in this area,
which is discussed further in the Emergency Services indicator.31
29. Cases 1, 2, 3, 9, 10, 11, 18, 19, 23, 24, and 27.
30. An echocardiogram is a procedure using an ultrasound to show the heart’s anatomy
and function.
31. Minor deficiencies were observed in cases 2, 10, and 15.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 53
Chronic Care
By appropriately managing chronic health care conditions, such as
diabetes, high blood pressure, and abnormal cholesterol levels, providers
decrease their patients’ risk of short- and long-term complications. In
most instances, VSP providers appropriately managed their patients’
chronic health conditions. Rare exceptions occurred in case 2 and the
following case:
• In case 10, clinic providers repeatedly failed to manage the
patient’s blood pressure, which resulted in multiple TTA visits.
Specialty Services
The providers appropriately referred patients for specialty consultations
when needed. When specialists made recommendations, providers
followed the recommendations correctly. Please refer to the Specialty
Services indicator for additional details regarding provider performance
in this area.
Documentation Quality
VSP providers demonstrated many opportunities for improvement
when documenting their decisions. Case reviewers found widespread
documentation errors.32 Poor documentation affected multiple areas of
patient care, including diagnoses, treatments, specialty care, and chronic
care. The following are examples of poor documentation:
• Providers did not record progress notes in cases 7, 8, 19, and 38.
• Providers did not document why they did not follow specialists’
recommendations in cases 1, 15, and 23.
• In case 19, multiple providers did not record progress notes when
prescribing antibiotics or performing procedures, and did not
record an elevated blood pressure reading. Although these lapses
did not affect the patient, they fell below standards of care.
Provider Continuity
Provider staffing at VSP was stable during this inspection period; there
was no provider staff turnover. In most cases, VSP providers properly
assessed their patients with chronic health conditions and appropriately
arranged follow-up appointments. As a result, VSP patients experienced
very good provider continuity. However, the following case is the
sole exception:
• In case 27, four primary care providers and four different
specialists evaluated the patient for prostate cancer and a
second tumor. The high number of providers involved and the
lack of care coordination resulted in delayed appointments and
treatment plans. As a result, VSP medical staff did not send the
32. Cases 1, 2, 7, 8, 10, 15, 18, 19, 23, and 38.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
54 Cycle 6 Medical Inspection Report
patient for his prostate cancer treatment until six months after
the initial diagnosis.
Clinician On‑Site Inspection
VSP held daily provider meetings before the clinic huddles. During the
meeting, the on-call provider discussed after-hours patients who were
evaluated in the TTA, sent to a higher level of care, or returned from off-
site specialist appointments. The care team nurses relayed information
concerning hospitalized patients and all patients who had upcoming
specialty appointments. Providers discussed any pertinent patient issues.
All VSP providers praised their physician managers. The CP&S covered
the TTA and OHU during providers’ unexpected absences, and also
reassigned providers to different clinics, ensuring appropriate medical
care for scheduled patients. Physician managers were available to answer
questions. Providers reported high morale and felt supported. Providers
said they appreciated the constructive feedback their managers gave
them regularly.
The physician managers expressed satisfaction with their providers’
performance. The institution employed nine providers: three advanced
practitioners and six physicians. Two of the six physicians were
telemedicine providers. The physician manager explained that the recent
difficulty recruiting on-site physicians led to converting two on-site
positions to remote telemedicine positions. According to the CME, all
VSP providers delivered high-quality care.
Recommendations
We offer no specific recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 55
Specialized Medical Housing
Overall
In this indicator, OIG inspectors evaluated the quality of care in the Rating
Adequate
specialized medical housing units. VSP’s only specialized medical
housing is an outpatient housing unit (OHU). Our clinicians focused
on medical staff’s ability to assess, monitor, and intervene for medically Case Review
complex patients requiring close medical supervision. Inspectors Rating
evaluated the timeliness and quality of provider and nursing intake Adequate
assessments and care plans. We assessed staff’s ability to respond
promptly when patients’ conditions deteriorated. Our clinicians looked Compliance
for good communication when staff consulted with one another while Score
Adequate
providing continuity of care. Our clinicians also interpreted relevant
compliance results and incorporated them into this indicator. (83%)
Results Overview
VSP providers and nurses delivered quality care in the OHU. Our
clinicians found sporadic opportunities for improvement in this area.
Although compliance testing found that OHU staff did not always deliver
medications timely, our clinicians determined that the delays did not
significantly increase the risk of patient harm. Overall, the OHU staff
performed well, resulting in an adequate rating for this indicator.
Case Review Results
OIG clinicians reviewed six OHU cases, which included 43 provider
events and 37 nursing events. Each provider and nursing event
can represent up to one month of care. Case reviewers identified
27 opportunities for improvement,33 five of which were significant. All
five significant opportunities for improvement occurred in one case
(case 3) and were related to provider performance.
Provider Performance
VSP providers usually delivered good care in the OHU. New patients
admitted to the OHU received thorough evaluations. The providers
followed up on their patients and reviewed test results appropriately.
Compliance testing confirmed VSP providers completed admission
history and physical examinations promptly, and evaluated their patients
at appropriate intervals (MIT 13.003, 90%).
The only significant opportunities for improvements were in case 3.
These deficiencies did not show any pattern of performance issues.
• In case 3, the patient underwent heart bypass surgery. The
provider did not order daily aspirin and the cardiology follow-
up appointment. Although the patient did not suffer graft
failure, these omissions fell below standards of care. On site, the
provider agreed.
33. These opportunities for improvement occurred in cases 3, 11, 23, 57, and 58.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
56 Cycle 6 Medical Inspection Report
• Later in case 3, the provider did not review and reorder
the patient’s cardiac rehabilitation appointments after
hospitalization. Subsequently, the patient did not receive any
further cardiac rehabilitation appointments.
Nursing Performance
OHU nurses performed timely admission assessments. Compliance
testing indicated nurses usually completed an initial assessment for
patients on the day of admission (MIT 13.001, 90%). Our clinicians found
one late admission assessment in the case reviews:
• In case 58, the OHU nurse did not obtain a full health history or
perform a thorough physical examination until the following day.
Although this did not affect the patient’s overall care, the nurse
did not follow OHU policy.
Most of the time, the OHU nurses checked on patients appropriately,
assessed their functional status, and provided care as ordered
by the provider. Case reviewers found isolated opportunities for
improvement when OHU nurses made incomplete nursing assessments
and interventions:
• In case 3, the OHU nurse did not complete an assessment when
the patient complained of a productive cough.
• In case 57, the nurses did not properly monitor the patient’s fluid
intake or weight per provider orders. Although this did not affect
the patient’s health outcome, this omission fell below nursing
standards of care.
• In case 58, the nurses did not follow provider orders to obtain the
patient’s vital signs every day. Although the patient was clinically
stable, this omission fell below nursing standards of care.
Medication Administration
In case review testing, clinicians found medication administration in the
OHU was occasionally delayed:
• In case 23, the pharmacy provided the patient’s inflammatory
bowel disease medication two days late.
Compliance testing showed that VSP had trouble administering
medications to patients timely after admitting patients to the OHU
(MIT 13.004, 50%). However, when our clinicians analyzed this low
score, we determined that the delays in administration were one-hour to
one-day late, and the medications were nonessential. Although there was
room for improvement in this area, the OHU patients usually received
their medications within clinically appropriate time frames.
Clinician On‑Site Inspection
The OHU had 20 medical beds, and all were in use during the case
review on-site inspection. Half the rooms in the OHU could also be
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 57
used as reverse isolation rooms, and all rooms had a working call-light
system present. Compliance testing found the call systems in all rooms
functioned properly, and staff had unimpeded access to the patient’s
rooms (MIT 13.101, 100%). The OHU staff conducted daily morning
huddles, during which they discussed patient care, with an emphasis on
pending consultations and specialty service appointments.
Recommendations
We offer no specific recommendations for this indicator.
Compliance Testing Results
Table 17. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Prior to 4/2019: Did the registered
nurse complete an initial assessment of the patient on the day of
admission, or within eight hours of admission to CMF’s Hospice? 9 1 0 90%
Effective 4/2019: Did the registered nurse complete an initial
assessment of the patient at the time of admission? (13.001) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time N/A N/A N/A N/A
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior
to 4/2019): Did the primary care provider complete the Subjective,
Objective, Assessment, and Plan notes on the patient at the 9 1 0 90%
minimum intervals required for the type of facility where the patient
was treated? (13.003) *, †
Upon the patient’s admission to specialized medical housing: Were
all medications ordered, made available, and administered to the 5 5 0 50%
patient within required time frames? (13.004) *
For OHU and CTC only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
1 0 0 100%
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells? (13.101) *
Overall percentage (MIT 13): 83%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still have
state-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
58 Cycle 6 Medical Inspection Report
Specialty Services
Overall
Rating In this indicator, OIG inspectors evaluated the quality of specialty
Adequate
services. The OIG clinicians focused on the institution’s ability
to provide needed specialty care. Our clinicians also examined
Case Review specialty appointment scheduling, providers’ specialty referrals,
Rating and medical staff’s retrieval, review, and implementation of any
Adequate specialty recommendations.
Compliance
Results Overview
Score
Proficient
VSP provided good specialty services and performed well in compliance
(89%)
testing. Providers referred their patients to specialists appropriately
and followed the specialists’ recommendations. Nurses also did well
with their assessments and interventions when their patients returned
from specialty consultations. VSP provided excellent specialty access
for patients already in the institution; yet, they had difficulty providing
timely specialty access for patients transferring into the institution with
preexisting referrals. In addition, the institution’s staff demonstrated
significant problems handling specialty reports; however, these errors
did not significantly impact specialty services. This indicator received an
adequate rating.
Case Review Results
OIG clinicians reviewed 143 events related to specialty services,
including 111 specialty consultations and procedures, and found
38 opportunities for improvement,34 three of which were significant.35
Most of the opportunities for improvement were related to processing
specialty reports.
Access to Specialty Services
Compliance testing showed VSP had excellent adherence to
policy-required time frames for routine-priority (MIT 14.007, 100%) and
high-priority (MIT 14.001, 100%) specialty referrals. VSP did not score as
well for patients who transferred into the institution with preapproved
specialty services; only 13 of 20 sampled patients (MIT 14.010, 65%)
received their specialty appointment on time.
Our clinicians also found VSP had good specialty access. Although
clinicians identified five opportunities for improvement,36 the errors
were not common and were unlikely to place patients at significant risk
of harm. Clinicians found one specialty referral that lapsed due to the
transfer process:
34. This occurred in cases 3, 7, 9, 10, 11, 12, 15, 18, 19, 20, 21, 22, 23, 25, 26, and 27.
35. Significant deficiencies were observed in cases 26 and 27.
36. Opportunities for improvement were noted in cases 18, 19, 22, 26, and 27.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 59
• In case 22, the patient transferred to another institution, but
returned to VSP. The provider did not review and reorder the
oral maxillofacial surgery follow-up appointment per policy.
Provider Performance
VSP providers performed well with specialty care, usually referring
their patients to specialists properly. Clinicians identified only one
opportunity for improvement in which the provider ordered the specialty
referral with the wrong priority:
• In case 26, the patient had shoulder surgery, and the orthopedic
specialist recommended a referral to physical therapy. The
provider inappropriately ordered routine-priority physical
therapy instead of urgent-priority, resulting in delayed therapy.
This delay contributed to the subsequent finding by the
orthopedic surgeon that the patient developed a restricted
active range of motion. On site, the provider acknowledged the
incorrect order.
Overall, providers gave appropriate follow-up care after the specialty
consultations. Compliance testing also found that providers usually
saw their patients promptly following a specialty appointment
(MIT 1.008, 82%).
Nursing Performance
The majority of VSP nurses made good assessments and interventions for
patients returning from off-site and telemedicine specialty appointments.
In addition, nurses appropriately informed providers of specialists’
findings and recommendations, obtained orders, and scheduled provider
follow-up appointments. Our clinicians reviewed 27 nursing encounters
and identified two opportunities for improvement.37 Although the
errors were infrequent, VSP should use the following example for
improvement purposes:
• In case 7, the nurse did not inform the patient of the correct
diabetic medication adjustments prior to his colonoscopy.
Health Information Management
VSP scored high marks with specialty report retrieval (MIT 4.002, 90%)
and provider signatures for high-priority and routine-priority specialty
reports (MIT 14.002, 93%, and MIT 14.008, 80%). However, clinicians
found delays in scanning and retrieval of specialty reports,38 as well as
37. Opportunities for improvement were found in cases 7 and 20.
38. The institution did not timely retrieve or scan specialty reports in cases 3, 9, 11, 18, 22,
23, 25, 26, and 27.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
60 Cycle 6 Medical Inspection Report
instances of providers not signing specialty reports.39 Please refer to the
Health Information Management indicator for additional details.
Clinician On‑Site Inspection
Our clinicians met with VSP’s medical managers, providers, nurses,
and ancillary staff. The specialty and utilization management nurses
were familiar with their patient population, as well as with their
responsibilities and duties. The nurses attended the morning provider
meeting and relayed pertinent updates for the patients. The providers
then transmitted this information to the care teams in the morning
clinic huddles.
The CP&S described the institution’s tracking processes for specialty
appointments and the subsequent provider follow-up appointments.
Providers reported no barriers when referring their patients to
specialists. However, according to the specialty schedulers, some of the
nearby specialists stopped serving VSP patients. The schedulers now
relied on the larger metropolitan areas for specialty services, but reported
limited specialty appointment availability.
VSP managers acknowledged the problems the OIG clinicians identified
with specialty report handling and reported they had already started
training ancillary staff to improve their handling of specialty reports.
Recommendations
We offer no specific recommendations for this indicator.
39. Providers failed to sign specialty reports in cases 7, 9, 10, 12, 15, 19, 21, 22, 23, 25, 26,
and 27.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 61
Compliance Testing Results
Table 18. 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 15 0 0 100%
Request for Service? (14.001) *
Did the institution receive and did the primary care provider review
the high-priority specialty service consultant report within the 14 1 0 93%
required time frame? (14.002) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 9 1 5 90%
provider? (14.003) *
Did the patient receive the medium-priority specialty service within
15-45 calendar days of the primary care provider order or Physician N/A N/A N/A N/A
Request for Service? (14.004) *
Did the institution receive and did the primary care provider review
the medium-priority specialty service consultant report within the N/A N/A N/A N/A
required time frame? (14.005) *
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary care N/A N/A N/A N/A
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 15 0 0 100%
Request for Service? (14.007) *
Did the institution receive and did the primary care provider review
the routine-priority specialty service consultant report within the 12 3 0 80%
required time frame? (14.008) *
Did the patient receive the subsequent follow-up to the routine-
priority specialty service appointment as ordered by the primary care 3 1 11 75%
provider? (14.009) *
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at the
13 7 0 65%
sending 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
19 1 0 95%
specialty services within required time frames? (14.011)
Following the denial of a request for specialty services, was the
patient informed of the denial within the required time frame? 19 0 1 100%
(14.012)
Overall percentage (MIT 14): 89%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
62 Cycle 6 Medical Inspection Report
Table 19. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up
23 5 2 82%
visits occur within required time frames? (1.008) *, †
Are specialty documents scanned into the patient’s electronic health
18 2 10 90%
record within five calendar days of the encounter date? (4.002) *
* The OIG clinicians considered these compliance tests along with their own case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician
follow-up visits following most specialty services. As a result, we test 1.008 only for high-priority specialty
services or when the staff orders PCP or PC RN follow-ups. The OIG continues to test the clinical
appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 63
Administrative Operations
Overall
In this indicator, OIG compliance inspectors evaluated health care Rating
administrative processes. Our inspectors examined the timeliness of Adequate
the medical grievance process and checked whether the institution
followed reporting requirements for adverse or sentinel events and Case Review
patient deaths. Inspectors checked whether the Emergency Medical Rating
Response Review Committee (EMRRC) met and reviewed incident (N/A)
packages. We investigated and determined if the institution conducted
the required emergency response drills. Inspectors also assessed whether Compliance
the Quality Management Committee (QMC) met regularly and addressed Score
Adequate
program performance adequately. In addition, the inspectors examined
if the institution provided training and job performance reviews for (83%)
its employees. They checked whether staff possessed current, valid
professional licenses, certifications, and credentials. The OIG rated this
indicator solely based on the compliance score, using the same scoring
thresholds as in the Cycle 4 and Cycle 5 medical inspections. Our case
review clinicians typically do not rate this indicator.
Because none of the tests in this indicator affected clinical patient
care directly (it is a secondary indicator), the OIG did not consider
this indicator’s rating when determining the institution’s overall
quality rating.
Recommendations
We offer no specific recommendations for this indicator.
Compliance Testing Results
Nonscored Tests
We obtained CCHCS Death Review Committee (DRC) reporting records.
After a patient dies, the DRC must complete a death review report within
60 calendar days for unexpected deaths and within 30 calendar days for
expected deaths. When the DRC completes the death review summary
report, it must submit the report to the institution’s CEO within seven
calendar days.
Two deaths occurred during the inspection review period, one
unexpected death and one expected death. The DRC did not complete the
death review reports on time. For the expected death, the DRC finished
the report 123 days late and did not notify the institution’s CEO of the
report. For the unexpected death, the DRC did not complete the final
death review report timely, which remained overdue at the end of the
inspection period (MIT 15.998).
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
64 Cycle 6 Medical Inspection Report
Compliance Testing Results
Table 20. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the
N/A N/A N/A N/A
institution meet RCA reporting requirements? (15.001)
Did the institution’s Quality Management Committee (QMC) meet
6 0 0 100%
monthly? (15.002)
For Emergency Medical Response Review Committee (EMRRC)
reviewed cases: Did the EMRRC review the cases timely, and did
3 9 0 25%
the incident 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 N/A N/A N/A N/A
operating 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 3 0 0 100%
custody staff participate in those drills? (15.101)
Did the responses to medical grievances address all of the inmates’
10 0 0 100%
grieved issues? (15.102)
Did the medical staff review and submit initial inmate death reports
2 0 0 100%
to the CCHCS Death Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance
5 2 2 71%
appraisals timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 12 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR),
Basic Life Support (BLS), and Advanced Cardiac Life Support (ACLS) 2 0 1 100%
certifications? (15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy 6 0 1 100%
maintain a valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
1 0 0 100%
Agency (DEA) registration certificates? (15.109)
Did nurse managers ensure their newly hired nurses received the
0 1 0 0
required onboarding and clinical competency training? (15.110)
This is a nonscored test. Please
Did the CCHCS Death Review Committee process death review
refer to the discussion in this
reports timely? (15.998)
indicator.
This is a nonscored test. Please
What was the institution’s health care staffing at the time of the OIG
refer to Table 4 for CCHCS-
medical inspection? (15.999)
provided staffing information.
Overall percentage (MIT 15): 83%
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 65
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 VSP
Access to Care
Emergency Health Care
W Services Diagnostic Services Environment C
O
E
I Health Information Management M
V
P
E Nursing Preventive
Transfers L
R Performance Services
I
A
E
Medication Management N
S
C
A
C Provider Specialized Medical Housing Administrative E
Performance Operations
Specialty Services
Source: The Office of the Inspector General medical inspection results.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
66 Cycle 6 Medical Inspection Report
Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the
recommendation of its stakeholders, which continues in the Cycle 6
medical inspections. Below, Table A–1 provides important definitions
that describe this process.
Table A–1. Case Review Definitions
The medical care provided to one patient over a
Case, Sample,
specific period, which can comprise detailed or focused
or Patient
case reviews.
A review that includes all aspects of one patient’s medical
Comprehensive care assessed over a six-month period. This review allows
Case Review the OIG clinicians to examine many areas of health care
delivery, such as access to care, diagnostic services, health
information management, and specialty services.
A review that focuses on one specific aspect of medical
Focused care. This review tends to concentrate on a singular
Case Review facet of patient care, such as the sick call process or the
institution’s emergency medical response.
A direct or indirect interaction between the patient and
the health care system. Examples of direct interactions
Event
include provider encounters and nurse encounters. An
example of an indirect interaction includes a provider
reviewing a diagnostic test and placing additional orders.
Case Review A medical error in procedure or in clinical judgment. Both
procedural and clinical judgment errors can result in policy
Deficiency
noncompliance, elevated risk of patient harm, or both.
Adverse Event An event that caused harm to the patient.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 67
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, nonclinician 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 standardized protocol and
select samples for clinicians to review. Samples are obtained per the
case review methodology shared with stakeholders in prior cycles.
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
scenarios 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.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
68 Cycle 6 Medical Inspection Report
Figure A–2. Case Review Testing
The OIG clinicians examine the chosen samples, performing either
a comprehensive case review or a focused case review, to determine
the events that occurred.
Sample = Patient = Case
No Deficiency
or Minor
Deficiency
Sample Events
Significant
Deficiency *
A sample leading to events
Deficiencies
Not all events lead to deficiencies (medical errors); however, if errors did
occur, then the OIG clinicians determine whether any were adverse.
Significant
Sample Events
Deficiency *
A sample leading to events that
could cause harm
Did the event
cause harm to
the patient?
* If an event (in this case,
a significant deficiency) caused harm,
the OIG clinician labels it adverse.
Yes No
AAddvveerrssee Significant
EEvveenntt Deficiency
Source: The Office of the Inspector General medical inspection analysis.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 69
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
Total Patient Population Filters
Subpopulation Randomize
Sample Flagging
Source: The Office of the Inspector General medical inspection analysis.
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.
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
70 Cycle 6 Medical Inspection Report
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 also obtain information regarding plant infrastructure
and local operating procedures.
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
(greater than 85 percent), adequate (between 75 percent and 85 percent),
or inadequate (less than 75 percent).
Indicator Ratings and the Overall Medical
Quality Rating
To reach an overall quality rating, our inspectors collaborate and
examine all the inspection findings. We consider the case review and the
compliance testing results for each indicator. After considering all the
findings, our inspectors reach consensus on an overall rating for
the institution.
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 71
Appendix B: Case Review Data
Table B–1. Case Review Sample Sets
Anticoagulation 4
CTC / OHU 3
Death Review / Sentinel Events 3
Diabetes 3
Emergency Services – CPR 2
Emergency Services – Non-CPR 3
High Risk 5
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 20
Specialty Services 4
57
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
72 Cycle 6 Medical Inspection Report
Table B–2. Case Review Chronic Care Diagnoses
Diagnosis Total
Anemia 6
Anticoagulation 4
Arthritis / Degenerative Joint Disease 3
Asthma 10
COPD 4
Cancer 6
Cardiovascular Disease 8
Chronic Kidney Disease 2
Chronic Pain 10
Cirrhosis / End-Stage Liver Disease 5
Coccidioidomycosis 2
Deep Venous Thrombosis / Pulmonary Embolism 3
Diabetes 17
Gastroesophageal Reflux Disease 10
Hepatitis C 17
Hyperlipidemia 27
Hypertension 26
Mental Health 22
Migraine Headaches 1
Seizure Disorder 5
Sleep Apnea 3
Thyroid Disease 3
194
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 73
Table B–3. Case Review Events by Program
Diagnosis Total
Diagnostic Services 181
Emergency Care 81
Hospitalization 37
Intrasystem Transfers In 10
Intrasystem Transfers Out 5
Not Specified 1
Outpatient Care 512
Specialized Medical Housing 103
Specialty Services 153
1,083
Table B–4. Case Review Sample Summary
MD Reviews Detailed 25
MD Reviews Focused 1
RN Reviews Detailed 17
RN Reviews Focused 28
Total Reviews 71
Total Unique Cases 57
Overlapping Reviews (MD & RN) 14
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
74 Cycle 6 Medical Inspection Report
Appendix C: Compliance Sampling Methodology
Valley State Prison
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least
Patients one condition per patient — any
risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 30 MedSATS • Clinic (each clinic tested)
(6 per clinic) • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 25 OIG Q: 4.005 • See Health Information
Community Management (Medical Records)
Hospital (returns from community hospital)
MIT 1.008 Specialty Services 30 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001 – 003 Radiology 10 Radiology Logs • Appointment date
(90 days – 9 months)
• Randomize
• Abnormal
MITs 2.004 – 006 Laboratory 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology related)
• Randomize
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 75
Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 20 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 20 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 20 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for any • Any misfiled or mislabeled
tested inmate document identified during
OIG compliance review (24 or
more = No)
MIT 4.005 Returns From 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 9 OIG inspector • Identify and inspect all on-site
MITs 5.107 – 111 on-site review clinical areas.
Transfers
MITs 6.001 – 003 Intrasystem Transfers 25 SOMS • Arrival date (3 – 9 months)
• Arrived from (another
departmental facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 9 OIG inspector • R&R IP transfers with medication
on-site review
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
76 Cycle 6 Medical Inspection Report
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
Community Hospital Management (Medical Records)
(returns from community hospital)
MIT 7.004 RC Arrivals — N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 0 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies OIG inspector • Identify and inspect clinical
Areas by test on-site review & med line areas that store
medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site
Preparation and by test on-site review clinical areas that prepare and
Administration Areas administer medications
MITs 7.108 – 111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 14 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 Isolation Unit KOP 1 On-site active • KOP rescue inhalers &
Medications medication listing nitroglycerin medications for IPs
housed in isolation units
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 77
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 8 Maxor • Dispense date (past 9 months)
• Time period on TB meds
(3 months or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior
Annual Screening to inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior
Vaccinations to inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior
Screening to inspection)
• Date of birth (51 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior
institution to inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs.
institution prior to inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require
vaccination(s)
MIT 9.009 Valley Fever N/A at this Cocci transfer • Reports from past 2 – 8 months
(number will vary) institution status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
78 Cycle 6 Medical Inspection Report
Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 008 RC N/A at this SOMS • Arrival date (2 – 8 months)
institution • Arrived from (county jail, return
from parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001 – 004 Specialized Health 10 CADDIS • Admit date (2 – 8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of
5 days)
• Rx count
• Randomize
MIT 13.101 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 MedSATS • Approval date (3 – 9 months)
Initial and Follow-Up • Remove consult to gynecology,
RFS consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, or podiatry
• Randomize
MITs 14.004 – 006 Medium-Priority N/A MedSATS • Approval date (3 – 9 months)
Initial and Follow-Up • Remove consult to gynecology,
RFS consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, or podiatry
• Randomize
MITs 14.007 – 009 Routine-Priority 15 MedSATS • Approval date (3 – 9 months)
Initial and Follow-Up • Remove consult to gynecology,
RFS consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, or podiatry
• Randomize
MIT 14.010 Specialty Services 20 MedSATS • Arrived from (other departmental
Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 20 InterQual • Review date (3 – 9 months)
• Randomize
0 IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 79
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.001 N/A – Adverse/sentinel • Adverse/Sentinel 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 LGB meeting • Quarterly meeting minutes
minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
MIT 15.103 Death Reports 2 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 9 On-site • All required performance
Evaluation Packets provider evaluation documents
evaluation files
MIT 15.106 Provider Licenses 12 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site • All staff
Response certification ◦ Providers (ACLS)
Certifications tracking logs ◦ Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
80 Cycle 6 Medical Inspection Report
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.109 Pharmacy and On-site listing • All DEA registrations
Providers’ Drug of provider DEA
Enforcement Agency registration #s
(DEA) Registrations & pharmacy
registration
Nursing Staff All document
New Employee
Orientations
Death Review
Committee
MIT 15.110 Nursing staff • New employees (hired within last
All
training logs 12 months)
MIT 15.998 OIG summary log: • Between 35 business days &
deaths 12 months prior
2
• Health Care Services death
reviews
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Valley State Prison 81
California Correctional Health Care
Services’ Response
March 30, 2020
Roy Wesley, Inspector General
Office of the Inspector General
10111 Old Placerville Road, Suite 110
Sacramento, CA 95827
Dear Mr. Wesley:
The Office of the Receiver has reviewed the draft report of the Office of the Inspector
General (OIG) Medical Inspection Results for Valley State Prison (VSP) conducted from
September 2018 to April 2019. California Correctional Health Care Services (CCHCS)
acknowledges the OIG findings.
Thank you for preparing the report. Your efforts have advanced our mutual objective of
ensuring transparency and accountability in CCHCS operations. If you have any questions
or concerns, please contact me at (916) 691-3747.
Sincerely,
DeAnna Gouldy
Associate Director
Risk Management Branch
California Correctional Health Care Services
cc: Clark Kelso, Receiver
Diana Toche, D.D.S., Undersecretary, Health Care Services, CDCR
Richard Kirkland, Chief Deputy Receiver, CCHCS
Katherine Tebrock, Chief Assistant Inspector General, OIG
Doreen Pagaran, R.N., Nurse Consultant Program Review, OIG
Jennifer Barretto, Director, Health Care Policy and Administration, CCHCS
R.Steven Tharratt, M.D., M.P.V.M., FACP, Director, Health Care Operations, CCHCS
Roscoe Barrow, Chief Counsel, CCHCS Office of Legal Affairs
Lara Saich, Deputy Director, Policy and Risk Management Services, CCHCS
Renee Kanan, M.D., Deputy Director, Medical Services, CCHCS
Barbra Barney-Knox, R.N., Deputy Director (A), Nursing Services, CCHCS
Annette Lambert, Deputy Director, Quality Management, CCHCS
Donald B. McElroy, Regional Health Care Executive, Region II, CCHCS
Meet Boparai, M.D., Regional Deputy Medical Executive (A), Region II, CCHCS
Laura Schaper, Regional Nursing Executive, Region II, CCHCS
Raul Recarey, Chief Executive Officer, VSP
Amanda Oltean, Staff Services Manager II, Program Compliance Section, CCHCS
Leticia Martinez, Staff Services Manager I, Program Compliance Section, CCHCS
Misty Palasik, Staff Services Manager I, OIG
CALIFORNIA CORRECTIONAL P .0. Box 588500
HEALTH CARE SERVICES Elk Grove, CA 95758
Report Issued: August 2020 Office of the Inspector General, State of California
Return to Contents
82 Cycle 6 Medical Inspection Report
(This page left blank for reproduction purposes.)
Office of the Inspector General, State of California Inspection Period: September 2018 – April 2019
Return to Contents
Cycle 6
Medical Inspection Report
for
Valley State Prison
OFFICE of the
INSPECTOR GENERAL
Roy W. Wesley
Inspector General
Bryan B. Beyer
Chief Deputy Inspector General
STATE of CALIFORNIA
August 2020
OIG