OIG
Wasco State Prison Cycle 7 Medical Inspection Report
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Cycle 7, Wasco State Prison | iii
Contents
Illustrations iv
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 6
Institution-Specific Metrics 7
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 14
Access to Care 14
Diagnostic Services 21
Emergency Services 27
Health Information Management 31
Health Care Environment 37
Transfers 48
Medication Management 54
Preventive Services 63
Nursing Performance 66
Provider Performance 72
Reception Center 78
Specialized Medical Housing 84
Specialty Services 89
Administrative Operations 98
Appendix A: Methodology 103
Case Reviews 104
Compliance Testing 107
Indicator Ratings and the Overall Medical Quality Rating 108
Appendix B. Case Review Data 109
Appendix C: Compliance Sampling Methodology 112
California Correctional Health Care Services’ Response 119
June 19, 2024, OIG Response to March 25, 2024, Letter Regarding WSP Report 120
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | iv
Illustrations
Tables
1. WSP Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. WSP Master Registry Data as of February 2023 7
3. WSP Health Care Staffing Resources as of February 2023 8
4. WSP Results Compared With State HEDIS Scores 10
5. Access to Care 18
6. Other Tests Related to Access to Care 19
7. Diagnostic Services 25
8. Health Information Management 34
9. Other Tests Related to Health Information Management 35
10. Health Care Environment 46
11. Transfers 51
12. Other Tests Related to Transfers 52
13. Medication Management 60
14. Other Tests Related to Medication Management 61
15. Preventive Services 64
16. Reception Center 81
17. Other Tests Related to Reception Center 82
18. Specialized Medical Housing 87
19. Specialty Services 95
20. Other Tests Related to Specialty Services 96
21. Administrative Operations 100
A–1. Case Review Definitions 104
B–1. WSP Case Review Sample Sets 109
B–2. WSP Case Review Chronic Care Diagnoses 110
B–3. WSP Case Review Events by Program 111
B–4. WSP Case Review Sample Summary 111
Figures
A–1. Inspection Indicator Review Distribution for WSP 103
A–2. Case Review Testing 106
A–3. Compliance Sampling Methodology 107
Photographs
1. Outdoor Waiting Area 37
2. Indoor Waiting Area 38
3. Individual Waiting Modules 38
4. Multiple Patients Received Service at the Same Time, Hindering Auditory Privacy 39
5. Expired Medical Supplies Dated September 2022 40
6. Expired Medical Supplies Dated May 2019 40
7. Staff Members Stored Food on a Long-Term Basis in the Medical Supply
Storage Room 41
8. Medical Supplies Stored Directly on the Floor 42
9. Manufacturer’s Temperature Guidelines Listed on Medical Supplies
Were Not Followed 42
10. Unsanitary Medical Supply Shelf 43
11. Damaged and Unsanitary Examination Room Floor 44
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care that the department provides
to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 2
As we did during Cycle 6, our office continues to inspect both those institutions
remaining under federal receivership and those delegated back to the department. There
is no difference in the standards used for assessing a delegated institution versus an
institution not yet delegated. By the end of the Cycle 7 inspection period for Wasco State
Prison, the institution had been delegated back to the department by the receiver.
We completed our seventh inspection of the institution, and this report presents our
assessment of the health care provided at this institution during the inspection period
from July 2022 to December 2022.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between November 2021 and March 2022, anticoagulation review between January 2023 to
March 2023, and emergency cardiopulmonary (CPR) reviews between March 2022 and June 2022.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 3
Summary: Ratings and Scores
We completed the Cycle 7 inspection of WSP in May 2023. OIG inspectors monitored the
institution’s delivery of medical care that occurred between July 2022 and December 2022.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at WSP inadequate. quality at WSP inadequate.
OIG clinicians (a team of physicians and nurse consultants) reviewed 54 cases, which
contained 925 patient-related events. They performed quality control reviews; their
subsequent collective deliberations ensured consistency, accuracy, and thoroughness.
Our OIG clinicians acknowledged institutional structures that catch and resolve mistakes
that may occur throughout the delivery of care. After examining the medical records, our
clinicians completed a follow-up on-site inspection in May 2023 to verify their initial
findings. The OIG physicians rated the quality of care for 18 comprehensive case reviews.
Of these 18 cases, our physicians rated 14 adequate and four inadequate. Our physicians
found no adverse events during this inspection.
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 418 patient records and 1,336 data points,
and used the data to answer 100 policy questions. In addition, we observed WSP’s
processes during an on-site inspection in February 2023.
The OIG then considered the results from both case review and compliance testing, and
drew overall conclusions, which we report in 14 health care indicators.5
5 The indicator for Prenatal and Postpartum Care did not apply to WSP.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 4
We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. WSP Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 5
Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies can be
minor or significant, depending on the severity of the deficiency. An adverse event occurs
when the deficiency caused harm to the patient. All major health care organizations
identify and track adverse events. We identify deficiencies and adverse events to
highlight concerns regarding the provision of care and for the benefit of the institution’s
quality improvement program to provide an impetus for improvement.6
The OIG did not find any adverse events at WSP during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 11 of the 14
indicators applicable to WSP. Of these 11 indicators, OIG clinicians rated six adequate
and five inadequate. The OIG physicians also rated the overall adequacy of care for each
of the 18 detailed case reviews they conducted. Of these 18 cases, 14 were adequate and
four were inadequate. In the 925 events reviewed, there were 301 deficiencies, 88 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 WSP:
• Correctional treatment center (CTC) nurses performed timely admission
assessments and care plans.
• Nurses performed well in the transfer-out process and the reception center
(RC) intake process for assessments and screenings.
• Patients frequently received new medications timely.
Our clinicians found the following weaknesses at WSP:
• Provider outpatient assessments were often incomplete with lapses in
decision-making and poor documentation.
• Nursing assessment and interventions showed opportunities for
improvement.
•
Medication management was problematic for chronic care and specialized
medical housing (SMH) medications.
6 For a further discussion of an adverse event, see Table A–1.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 6
Compliance Testing Results
Our compliance inspectors assessed 11 of the 14 indicators applicable to WSP. Of these
11 indicators, our compliance inspectors rated one proficient, five adequate, and five
inadequate. We tested policy compliance in Health Care Environment, Preventive
Services, and Administrative Operations as these indicators do not have a case review
component.
WSP showed a high rate of policy compliance in the following areas:
• Nurses and providers did an excellent job completing nursing and provider
assessment of patients admitted to the specialized medical housing within
required time frames.
• Medical staff performed well in scanning health care services request forms,
specialty service reports, and community hospital discharge reports.
• Nurses at WSP reviewed health care services request forms and conducted
face-to-face encounters within required time frames. In addition, WSP
housing units contained adequate supplies of health care services request
forms.
WSP showed a low rate of policy compliance in the following areas:
• WSP’s medical warehouse and clinics stored multiple medical supplies that
had expired.
• Nurses did not regularly inspect emergency medical response bags and
treatment cart.
• Staff did not always ensure patients receive their chronic care medications
within required time frames. Poor medication continuity occurred for
patients returning from hospitalizations, for patients transferring from
county jails, and transferring into, within, and laying over at WSP.
• Staff did not properly store nonnarcotic refrigerated and nonrefrigerated
medications.
• Staff did not consistently follow universal hand hygiene precautions either
during patient encounters, or while distributing medications to patients.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 7
Institution-Specific Metrics
Wasco State Prison (WSP), located in Wasco, Kern County, houses medium-custody
general population, reception center, and minimum-custody incarcerated people. At the
time of our inspection, the incarcerated population was 3,761. WSP is designated as a
reception center, providing general outpatient health care services through its 11 clinics,
which handle nonurgent requests for medical services. Patients needing urgent or
emergent care are treated in its triage and treatment area (TTA), and inpatient health
services in its correctional treatment center (CTC).7
In February 2023, the Health Care Services Master Registry showed WSP had a total
population of 3,761. A breakdown of the medical risk level of the WSP population as
determined by the department is set forth in Table 2 below.8
Table 2. WSP Master Registry Data as of February 2023
7 For more information, see the department’s statistics on its website page titled Population COVID‑19
Tracking.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 8
According to staffing data the OIG obtained from California Correctional Health Care
Services (CCHCS), as identified in Table 3 below, WSP had one vacant executive
leadership position, 2.5 primary care provider vacancies, 0.7 nursing supervisor vacancy,
and 14.2 nursing staff vacancies.
Table 3. WSP Health Care Staffing Resources as of February 2023
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco 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 7. Likewise, Kaiser (commercial plan)
no longer publishes HEDIS scores. However, through the California Department of
Health Care Services’ Medi‑Cal Managed Care Technical Report, the OIG obtained
California Medi-Cal and Kaiser Medi-Cal HEDIS scores to use in conducting our
analysis, and we present them here for comparison.
HEDIS Results
We considered WSP’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. Currently, only one HEDIS
measure is available for review: poor HbA1c control, which measures the percentage of
diabetic patients who have poor blood sugar control. WSP’s results compared favorably
with those found in State health plans for this measure. We list the applicable HEDIS
measures in Table 4.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)— WSP’s
percentage of patients with poor HbA1c control was significantly lower, indicating very
good performance on this measure.
Immunizations
Statewide comparative data were also not available for immunization measures; however,
we include these data for informational purposes. WSP had a 35 percent influenza
immunization rate for adults 18 to 64 years old. The influenza immunization rate for
adults 65 years of age and older was not available.9 The pneumococcal immunization rate
was also not available.10
Cancer Screening
Statewide comparative data were not available for colorectal cancer screening; however,
we include these data for informational purposes. WSP had a 50 percent colorectal cancer
screening rate.
9 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable result. The
sample for older adults did not yield a full sample.
10 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines (PCV13,
PCV15, and PCV20), or 23 valent pneumococcal vaccine (PPSV23), depending on the patient’s medical
conditions. For the adult population, the influenza or pneumococcal vaccine may have been administered at a
different institution other than the one where the patient was currently housed during the inspection period.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 10
Table 4. WSP Results Compared With State HEDIS Scores
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 11
Recommendations
As a result of our assessment of WSP’s performance, we offer the following
recommendations to the department:
Access to Care
• Medical leadership should determine the root causes of challenges in
providing timely provider reception center (RC) health care assessment,
chronic care follow-up appointments, routine specialty and follow-up
appointments, and nurse-to-provider referrals, and should implement
remedial measures as appropriate.
Diagnostic Services
• Medical leadership should determine the root cause of challenges to
notification and endorsement of routine and STAT laboratory results and
should implement remedial measures as appropriate to ensure STAT
laboratory tests are performed and providers notified within required time
frames.
• Medical leadership should ascertain the causes of the untimely provision of
laboratory services and should implement remedial measures as appropriate.
Emergency Services
• Nursing leadership should determine the root cause of challenges that
prevent staff in completing thorough assessments, timely interventions, and
accurate documentation after an emergent event and implement remedial
measures as indicated.
• The Emergency Medical Response Review Committee (EMRRC) should
thoroughly review emergency response events and ensure the emergency
response checklist review has identified the specific findings or training
issues.
Health Information Management
• Medical leadership should ensure all specialty reports, including on-site
specialty reports, are timely endorsed by providers.
• Medical leadership should establish a mechanism to ensure either the
specialist or on-site primary care providers timely endorse all diagnostic
studies that were ordered by on-site specialty providers and are reported in
the medical record.
• Medical leadership should determine the root cause of challenges in sending
patient notification letters communicating laboratory tests and pathology
results, and should implement remedial measures as appropriate, including
ensuring clinic providers create patient notification letters with all four
elements required by CCHCS policy.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 12
Health Care Environment
• Executive leadership should consider performing random spot checks to
ensure clinics, medical storage rooms, and restrooms are cleaned properly
and timely.
• Medical leadership should remind staff to follow all applicable steps of the
universal hand hygiene procedure. Implementing random spot checks could
improve compliance.
• Executive leadership should consider performing random spot checks to
ensure medical supply storage areas, located outside the clinics, store
medical supplies adequately.
• Nursing leadership should direct each clinic nurse supervisor to review the
monthly emergency medical response bag (EMRB) and treatment cart logs to
ensure the EMRBs and treatment carts are regularly inventoried and sealed.
Transfers
• Nursing leadership should determine the root cause of challenges that
prevent nurses in thoroughly completing the initial health screening process
including answering all questions and documenting an explanation for all
“Yes” answers before the patient is transferred to the housing unit and
implement remedial measures as appropriate.
Medication Management
• The institution should consider developing and implementing measures to
ensure staff timely make available and administer medications to patients
and document administering medications in the EHRS as described in
CCHCS policy and procedures.
Preventive Services
• Nursing leadership should analyze the challenges to ensuring
nursing staff monitor and address symptoms of patients receiving TB
medications according to CCHCS guidelines and take necessary
remedial measures.
• Nursing leadership should analyze the challenges in ensuring patients at the
highest risk of coccidioidomycosis (Valley Fever) are monitored and
transferred in a timely manner.
• Medical and nursing leadership should analyze the challenges
related to the untimely provision of preventive vaccines to chronic
care patients and implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 13
Nursing Performance
• Nursing leadership should analyze the challenges to nurses performing
thorough, detailed assessments and interventions during patients’
appointments and reenforce the audits already implemented.
Provider Performance
• Medical leadership should analyze the causes of poor provider
documentation, including updating the patient problem lists, and implement
remedial measures as appropriate.
• Medical leadership should emphasize the necessity and importance of
appropriate provider EHRS chart review at each patient appointment.
• Medical leadership should clarify for providers the tasks required for RC-
focused health care assessments, appropriate durations for follow-up, and
expectations of the yard providers at the initial appointment after completing
focused health care assessments.
Reception Center
• Medical leadership should determine causative factors related to the
untimely provision of patients’ RC screening laboratory tests and provider
communication of test results to their patients as stated in CCHCS policy.
• Nursing leadership should analyze the challenges to nursing staff on
following CCHCS policies and procedures for coccidioidomycosis (Valley
Fever) skin test reading and implement remedial measures as appropriate.
Specialized Medical Housing
• Nursing leadership should analyze the causes of CTC nurses not completing
daily assessments thoroughly and implement remedial measures as
appropriate.
• Medical leadership should analyze the causes of CTC providers not
completing appropriate documentation, EHRS chart reviews, and not
addressing important medical issues.
Specialty Services
• CCHCS and WSP medical leadership should consider developing and
implementing strategies to improve communication with county jails to
ensure WSP can be prepared for the medical needs of high-risk patients on
their arrival.
• Medical leadership should determine causative factors related to the
untimely provision or scheduling of patients’ specialty service appointments
and implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 14
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing
patients with timely clinical appointments. Our inspectors reviewed scheduling and
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
specialists. Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (82.1%)
Compared with Cycle 6, during which WSP excelled at access to care, our case review
clinicians found WSP’s Cycle 7 performance was sufficient. Nurses reviewed patient
health care requests for services timely and completed face-to-face visits with patients
within one business day for symptomatic sick calls. Outpatient clinic and specialized
medical housing provider access was good. Providers saw patients after transfer-in,
posthospitalization, and follow-up care after high-priority specialty services; however,
they usually did not perform new reception center patient history and physical
examinations within required time frames, even for high-risk patients. We also found
specialty services appointments that should have been ordered urgently. Considering all
factors, the OIG rated the case review component of this indicator adequate.
Compliance testing showed WSP performed sufficiently in providing access to care. Staff
performed excellently in reviewing patient sick call requests and completing face-to-face
encounters, while showing good performance in completing provider follow-up
appointments for patients returning from specialty services. However, WSP scored low in
completing follow-up appointments for patients with chronic care conditions, patients
transferring into the institution, and patients returning from hospitalization. Factoring
in all the information, the OIG rated the compliance testing component of this indicator
adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 202 provider, nursing, urgent or emergent care (TTA), specialty,
and hospital events that required WSP to generate appointments. We identified 16
deficiencies relating to Access to Care, eight of which were significant.11
Access to Care Providers
Access to clinic providers is an integral part of patient care in health care delivery. WSP’s
performance was mixed in providing access to provider-ordered follow-up appointments.
11 Deficiencies occurred in cases 2, 7, 8, 10, 13, 16, 17, 20, 21, 52, and 53. Significant deficiencies occurred in
cases 2, 7, 16, 20, 21, and 52.
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 15
Case review found three nonsignificant deficiencies in the scheduling of outpatient
provider appointments, while compliance testing showed access to chronic care follow-
up appointments (MIT 1.001, 64.0%) and access to nursing and to primary care provider
sick call referrals (MIT 1.005, 71.4%) needed improvement.12
Access to Specialized Medical Housing Providers
WSP provided excellent access to specialized medical housing providers. OIG clinicians
did not identify any deficiencies.
Access to Clinic Nurses
WSP performed well in access to nurse sick calls and provider-to-nurse referrals.
Compliance testing found WSP performed excellently in reviewing patient health care
requests for services the same day they were received (MIT 1.003, 100%) and in
completing face-to-face appointments with patients within one business day for
symptomatic sick calls (MIT 1.004, 94.3%). Our clinicians reviewed 71 nursing sick call
requests and identified one nonsignificant deficiency related to clinic nurse access.13
Access to Specialty Services
WSP’s performance was mixed in referrals to specialty services. Compliance testing
determined WSP maintained a very good completion rate of high-priority (MIT 14.001,
86.7%), and excellent completion rates of medium-priority (MIT 14.004, 100%) and routine
(MIT 14.007, 100%) appointments. Case review found WSP on-site services such as
hemodialysis and podiatry visits occurred timely; however, WSP performed poorly in
obtaining off-site specialty appointments due to either providers not ordering services
timely or the appointments occurring outside of compliance. In three instances, patients
received delayed or no care because the necessary specialty services were not ordered due
to lack of specialty service appointment availability.14
Follow-Up After Specialty Services
WSP performed well in ensuring provider follow-up after specialty services appointments
occurred within required time frames. Compliance testing revealed nearly all provider
appointments after specialty services occurred within required time frames (MIT 1.008,
92.7%). OIG clinicians identified one nonsignificant deficiency in case 10. However, most
specialty referrals reviewed were not high priority and, therefore, did not require a
provider follow-up appointment per CCHCS policy.15
Follow-Up After Hospitalization
WSP’s performance in provider hospital follow-up was mixed. Compliance testing found
WSP’s performance needed improvement; providers inconsistently saw the patient timely
12 Deficiencies in provider access occurred in cases 10, 13, and 17.
13 A deficiency in nurse access occurred in case16.
14 Required specialty services were not ordered or delayed due to unavailability of specialists in case 20 and two
instances in case 52.
15 https://cchcs.ca.gov/wp-content/uploads/sites/60/HC/HCDOM-ch03-art1.11.pdf
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 16
following hospitalization (MIT 1.007, 64.7%). Case review examined three
hospitalizations, and patients were seen timely on return in each case.
Follow-Up After Urgent or Emergent Care
Providers saw their patients following a triage and treatment area (TTA) event as
requested. OIG clinicians reviewed seven TTA events and identified no delays in provider
follow-up appointments.
Follow-Up After Transferring Into WSP
Access to care for patients who had recently transferred into WSP was poor. Compliance
testing showed access to intake appointments for newly arrived patients needed
improvement (MIT 1.002, 52.2%). Our clinicians evaluated 12 transfer-in events; three
were transfers from other prisons, and nine were new RC patients. We found no delays in
following up after transferring in from other prisons; however, three significant
deficiencies were identified with the provider RC health care assessment as identified
below:
• In case 2, the newly arrived patient did not receive the required provider RC
health care assessment until 14 days after the compliance date.
• In case 7, an elderly male with history of daily alcohol abuse, known high
blood pressure, and gastroesophageal reflux transferred into WSP from the
county jail. The patient was seen by a provider for the RC health care
assessment 15 days late.
• In case 20, the patient with high-risk medical conditions including end-stage
kidney disease on dialysis, diabetes, heart failure, possible bladder cancer,
and blood in the urine was not seen for the provider RC health care
assessment until 15 days after arrival. This high-risk patient should have
been seen urgently.
This topic is also discussed in the Reception Center and Provider Performance
indicators. Case review did not identify any access deficiencies for nursing RC
appointments.
Clinician On-Site Inspection
Our case review clinicians spoke with WSP’s medical and nursing leadership, and
schedulers regarding WSP’s access to care. WSP has a dedicated hemodialysis unit,
operated by a contract vendor and overseen by WSP leadership. WSP also has a two-bed
TTA, a CTC, an RC, and multiple medical clinics. Medical leadership stated space has
been a significant challenge and new projects to correct this are underway. The RC is
being expanded to allow new patient medical, dental, visual, and mental health
evaluations to occur in one location. The TTA and two clinics are also being expanded.
WSP is one of the few RCs in the State prison system, and medical leadership reported
this institution provides intake and short-term patient housing. Its mission is to ensure
patients are medically stable until they are transferred to their next institution, which
should happen without significant delay. WSP medical leadership and providers
Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7, Wasco State Prison | 17
discussed how this can provide a challenge of balancing acute needs prior to transfer
versus waiting for treatment until transferred when more long-term care can be provided.
Both scheduling management and medical leadership stated provider follow-up after RC
arrival was poor due to COVID-19 and quarantine. COVID-19 testing occurred prior to
transfer from the county jails per protocol, and only patients with negative COVID-19
tests could be accepted. In addition, patients were tested again multiple times at WSP
prior to release from quarantine. Nursing staff saw patients as scheduled; however,
providers did not perform patient RC health care assessments as needed. We spoke with
medical leadership and asked why providers did not see newly arrived patients timely.
The chief medical executive (CME) responded this was due to a shortage of personal
protective equipment (PPE), as well as low levels of non-health-care custody and
physician staff. However, the CME’s written responses indicated the physicians were
fully staffed. In addition, initial nurse visits were timely, and no PPE or custody issues
were mentioned as obstacles for timely completing their visits.
WSP has a waiver from the California Department of Public Health, which extends the
duration between provider appointments in the CTC for up to 14 days and in the
outpatient housing unit (OHU) for up to 30 days. This extension improves provider access
compliance in specialized medical housing units.
Compliance On-site Inspection and Discussion
Patients had excellent access to health care services request forms in all six housing units
inspected (MIT 1.101, 100%).
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Compliance Testing Results
Table 5. Access to Care
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Table 6. Other Tests Related to Access to Care
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Recommendations
• Medical leadership should determine the root causes of challenges in
providing timely provider RC health care assessment, chronic care follow-up
appointments, routine specialty and follow-up appointments, and nurse-to-
provider referrals, and should implement remedial measures as appropriate.
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Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s performance in timely
completing radiology, laboratory, and pathology tests. Our inspectors determined
whether the institution properly retrieved the resultant reports and whether providers
reviewed the results correctly. In addition, in Cycle 7, we examined the institution’s
performance in timely completing and reviewing immediate (STAT) laboratory tests.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (60.8%)
As in Cycles 5 and 6, WSP performed well in radiology test completion, pathology report
results retrieval, and provider test result endorsement. Staff performed sufficiently in
completing initial intake screening and routine laboratory testing; however, we identified
several significant deficiencies. In addition, important point-of-care urine dip tests were
not available, causing a delay of care to ill patients. Taking these factors into
consideration, the OIG’s case review team rated this indicator adequate.
Compliance testing showed WSP performed exceptionally in providing radiology services
and in endorsing radiology, laboratory, and pathology results. However, WSP needed
improvement in completing routine and important STAT (immediate) laboratory tests
and generating patient letters that included all required key elements. On balance, the
OIG rated the compliance testing component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 189 diagnostic events and found 38 deficiencies, eight of which were
significant. Most of the nonsignificant deficiencies were due to missing patient results
letters or missing result letter components. Of the eight significant deficiencies, four
related to test completion and the other four pertained to the unavailability of important
point-of-care urine analysis testing.16
Test Completion
WSP diagnostic test completion results were mixed. Both compliance testing and case
review found WSP performed excellently when completing radiology services (MIT 2.001,
100%). WSP completed all tests timely and obtained reports. However, compliance
testing found the institution performed poorly in completing routine and STAT
laboratory services (MIT 2.004, 50.0% and MIT 2.007, 40.0%) within required time frames.
The case review team identified seven laboratory test completion deficiencies, three of
which were significant. The significant deficiencies were found in the following cases:
16 Deficiencies occurred in cases 1, 2, 8–12, 14–17, 19–21, 53, and 54. Significant deficiencies occurred in cases
10, 14, 16, and 20.
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• In case 16, a follow-up blood count laboratory test for an anemic (low red
blood cell counts) hemodialysis patient was ordered to be completed in four
days. The test was not performed as ordered.
• In case 20, the provider ordered a urine laboratory test to be performed in
nine days for a patient with a history of bladder cancer and symptoms of
blood in the urine. However, the test was not completed as ordered.
• Also in case 20, the provider ordered a blood test to follow up with a patient
just released from the hospital with severe anemia. The test was ordered to
be performed in four days; however, it was not completed until eight days
later. For a patient with potential blood loss, follow-up blood work is critical
to ensure the patient is stable.
Case review found a pattern in which three of nine RC patients’ screening laboratory
tests were either not completed or not completed timely:
• In case 2, several RC screening laboratory tests were collected one day late.
• In case 7, the patient’s intake screening laboratory tests, including tests for
tuberculosis, syphilis, HIV, hepatitis, and chicken pox immunity were
completed 13 days late.
• In case 54, the newly arrived patient returned from an outside hospital. The
patient’s screening intake laboratory tests for syphilis, HIV, hepatitis panels,
and tuberculosis were not reconciled on the patient’s return and were not
completed. The provider reordered them a few months later.
Case review found four significant delays in patient care due to lack of urine dipstick
tests at WSP in cases 10, 14, and 20. POC urine dipstick tests are rapid urine analysis
tests that can be performed in the clinic. Below are examples of significant deficiencies
related to the lack of this test at WSP:
• In case 10, the registered nurse (RN) contacted the provider about a diabetic
patient complaining of left-side flank pain during urination. The provider
ordered urinalysis to be done in seven days. A urine dipstick test should have
been performed immediately for assessment of the patient’s symptoms;
however, this test was not available.
• Also in case 10, the licensed vocational nurse (LVN) informed the provider
the patient had a critically elevated blood sugar of 500. A urine dipstick test
to evaluate for ketoacidosis should have been performed; however, this test
was not available.17
• In case 14, the RN contacted the provider for the patient’s complaint of
severe abdominal pain, nausea, headache, and dizziness lasting for one week.
17 Diabetic ketoacidosis is a diabetic complication in which the patient’s body produces excess blood acids
called ketones. This condition can be life-threatening and requires the patient to be hospitalized for treatment.
Ketones can be identified quickly by point of care tests, such as a urine dipstick.
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A urine dipstick test should have been performed; however, this test was not
available.
• In case 20, the RN assessed the patient who was complaining of blood in the
urine. This can be a symptom of urinary tract infection, which requires
immediate treatment. The provider could not order the necessary POC urine
dipstick test because it was unavailable.
We classified these deficiencies as patient care environment deficiencies that are
discussed further in the Clinician On-Site Inspection area below.
Health Information Management (HIM)
HIM performance for diagnostic reports was mixed. Staff retrieved laboratory and
diagnostic results promptly and sent them to providers for review. Compliance testing
showed providers endorsed both radiology (MIT 2.002, 90.0%) and laboratory (MIT 2.005,
100%) results timely; however, they performed poorly in communicating the radiology
and laboratory results to patients (MIT 2.003, 40.0% and MIT 2.006, 10.0%). Case review
findings were consistent. Our clinicians found issues with missing patient results letters
or letter components; however, none of those deficiencies was considered severe.
Compliance testing found nurse notification of STAT laboratory test results was poor
(MIT 2.008, 20.0%). In contrast, health care providers performed excellently in endorsing
the STAT laboratory test results within required time frames (MIT 2.009, 100%). Case
review identified one minor endorsement deficiency in case 3.
WSP performed well in obtaining pathology reports, and providers endorsed the reports
within required time frames (MIT 2.010, 80.0%, and MIT 2.011, 100%); however, providers
never communicated these pathology results to patients within required time frames
(MIT 2.012, zero).
OIG clinicians identified a pattern in which blood tests were ordered by the on-site
hemodialysis kidney specialist, but these results in patients’ medical records were not
endorsed by either the specialist or providers. Provider endorsements indicate laboratory
studies were reviewed. Only one deficiency, however, was considered significant:
• In case 16, the patient’s blood count test was low, showing a significant drop
from the previous test. This can indicate acute, life-threatening bleeding or
red blood cell destruction. The laboratory tests were ordered by the specialist
and were available for review in the EHRS, but they were not endorsed by any
on-site provider. The on-site providers were not aware of the acute drop in
blood count and did not order a timely workup to investigate the cause.
These deficiencies are discussed further in the Clinician On-Site Inspection area below.
Clinician On-Site Inspection
We met with medical and nursing leadership, diagnostic management and staff, and
hemodialysis unit RNs. Diagnostic leadership stated radiology was fully staffed during
the review period; however, two laboratory positions are currently vacant.
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Diagnostic leadership mentioned COVID-19 did not affect radiology but affected
laboratory services in multiple ways during the review period. The laboratory was short-
staffed due to staff illness. During this period, patient transfers from county jails
increased, which increased required tests for both COVID-19 routine screenings and
ISUDT urine toxicology testing.18 The leadership further reported, during the six-month
review period, 7,000 COVID-19 tests were performed. COVID-19 quarantine restrictions
and related patient access also contributed to a laboratory backlog.
The on-site hemodialysis unit (HDU), which is run by a contracted vendor, performs the
kidney specialty-ordered laboratory tests, processed through WSP’s laboratory. Those
laboratory results are entered into a patient’s medical record for all staff to access. This is
beneficial because on-site providers have access to the laboratory testing. Also, potential
kidney transplant recipients require immediate, up-to-date medical information to be
included in their transport packages should a transplant kidney become available. HDU
nursing stated they review all patient laboratory work from the day before, they inform
patients of the test results on the next dialysis appointment (which usually occurs three
times a week), and manage abnormal laboratory work by established protocols or contact
the kidney specialist. Medical leadership remarked the nephrologist has remote access to
patient medical records and reviews the results in a timely manner, but is not required to
endorse patient laboratory results. At times, this makes it difficult to determine whether
an on-site WSP provider is aware of laboratory test results unless a progress note is
documented in the EHRS or a follow-up order is entered.
We took these processes into consideration in our review of the cases. CCHCS policy
states all laboratory testing must be endorsed by a provider and patients should be
notified of the results.19 In addition, a medical provider should be reviewing the complete
medical record and responding accordingly. To be consistent with policy, the OIG cited a
lack of endorsements and missing patient results letters when there was no evidence the
results were communicated to the patient. However, we did not consider those
deficiencies as severe except for the one instance discussed above. At times, we found
evidence in the EHRS that, although the specialty-ordered laboratory work was not
endorsed, the nephrologist was reviewing and acting on the results because follow-up
orders were being entered in the EHRS. Because of the established dialysis protocols
provided to us at the on-site inspection, we did not usually cite for missing nephrology
progress notes that would detail why the additional laboratory tests were ordered.
Continuity of care and a clear medical record is critical to patient safety regardless of the
source of the medical record data. We did, therefore, cite missing progress notes when
medical decision-making regarding new laboratory orders was not clear.
18 ISUDT is the Integrated Substance Use Disorder Treatment program.
19 Refer to https://cchcs.ca.gov/wp-content/uploads/sites/60/HC/HCDOM-ch03-art1.14.pdf.
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Compliance Testing Results
Table 7. Diagnostic Services
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Recommendations
• Medical leadership should determine the root cause of challenges to
notification and endorsement of routine and STAT laboratory results and
should implement remedial measures as appropriate to ensure STAT
laboratory tests are performed and providers notified within required time
frames.
• Medical leadership should ascertain the causes of the untimely provision of
laboratory services and should implement remedial measures as appropriate.
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Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed emergency medical services by examining the timeliness and
appropriateness of clinical decisions made during medical emergencies. Our evaluation
included examining the emergency medical response, cardiopulmonary resuscitation
(CPR) quality, triage and treatment area (TTA) care, provider performance, and nursing
performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services.
The OIG assessed the institution’s emergency services mainly through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
WSP performed satisfactorily for emergency services. Case review found staff generally
delivered timely and appropriate care, and providers performed well with emergency
care. However, we also found opportunities for improvement in nursing assessment,
interventions, and documentation. In addition, WSP’s EMRRC did not identify some
nurses’ deficiencies we identified. Factoring in all the information, the OIG rated this
indicator adequate.
Case Review Results
We reviewed 18 urgent and emergent events in 12 cases.20 We found 18 emergency-related
deficiencies, three of which were significant.21
Emergency Medical Response
WSP staff responded promptly to emergencies throughout the institution. They initiated
CPR appropriately, activated emergency medical services (EMS), and notified TTA staff
in a timely manner.
Cardiopulmonary Resuscitation Quality
During this period, we reviewed five cases in which cardiopulmonary resuscitation (CPR)
was initiated.22 Custody and medical staff generally worked cohesively to provide care,
move the patient to the TTA for additional interventions, and transfer the patient to a
higher level of care. Staff activated the 9-1-1 system from the scene. Below is one case of a
delay in interventions. The patient was pronounced dead by EMS at the institution:
20 Urgent and emergent events occurred in cases 1-7, 14, 15, and 18-20.
21 Emergency deficiencies occurred in cases 1-3, 5, 15, and 18–20. Significant deficiencies occurred in cases 5
and 20.
22 CPR occurred in cases 3–7.
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• In case 5, medical emergency care was provided to an unconscious patient
due to a possible drug overdose. Nurses documented the patient was found
with shallow irregular respiration, as well as no spontaneous respirations,
and a weak and thready carotid pulse. Nurses did not reassess the patient’s
respiratory status while en route to the TTA. Also, the documentation on the
patient’s neurological status was inconsistent. When nursing staff initially
found the patient did not have spontaneous respirations prior to arriving in
the TTA, nurses did not document either the rate of the shallow respirations
or the carotid pulse rate and did not initiate high-flow oxygen via a bag valve
mask. Nurses also did not initiate the automated external defibrillator (AED)
on scene when the patient had a weak and thready carotid pulse until the
patient had no pulse eight minutes later in the TTA.
Provider Performance
Providers generally performed well in urgent situations, emergent situations, and after-
hours care. They frequently documented the emergent events, although the OIG found
missing provider documentation in two cases. However, our clinicians found no
significant provider performance deficiencies.
Nursing Performance
Nurses performed very well during emergent events. The TTA nurses responded
promptly when a medical alarm was activated, made sound medical decisions, and timely
consulted a provider. However, we identified opportunities for improvement when nurses
did not provide a thorough patient assessment or reassessment. The following are
examples:
• In case 1, nurses provided emergency care for an unconscious patient due to
a possible overdose. However, nurses did not assess neurological status after
the initial assessment in the TTA until EMS arrived approximately 14
minutes later. In addition, the OIG found time-line documentation
discrepancies in which nurses documented vital signs, neurological status, a
skin assessment, and radial pulse after the patient had departed for the
hospital.
• In case 15, nurses provided emergency care for a patient who fell on the way
to dialysis and complained of right ankle pain. The nurse did not assess
range of motion in the right ankle, provide support to immobilize the right
ankle pending a STAT X-ray per provider orders, and did not obtain orders
for either crutches or a temporary wheelchair.
• In case 20, the patient had a witnessed fall and an unwitnessed fall. Early in
the review period, the patient had a witnessed fall, which was due to
weakness in his legs, and the LVN consulted with the RN. However, the RN
did not document the phone consultation and did not perform a postfall
assessment until over six hours later. Later in the review period, the patient
had an unwitnessed fall, which was due to the broken wheelchair, and the
patient hit his head. We identified deficiencies with the documentation time
line, missing vital signs checks including orthostatic blood pressure,
incomplete assessments of the extremities, a lack of a risk assessment for
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falling, and a lack of a reassessment for a low pulse rate. Lastly, the RN did
not consult with the provider for the unwitnessed fall.
Nursing Documentation
Nurses in the TTA usually performed thorough documentation for emergent events.
Although we identified deficiencies for time lines and medication administration, these
did not affect overall patient care.23
Emergency Medical Response Review Committee
The EMRRC met monthly. The OIG compliance team found incomplete checklists (MIT
15.003, zero). Our clinicians found clinical reviews were performed by the nursing
supervisors; however, they did not identify incomplete assessments or conflicting time
lines.24
Clinician On-Site Inspection
Our clinicians toured the TTA during our on-site inspection. The TTA has two beds,
which provided sufficient space for emergency care, and also one crash cart, one
Omnicell, an AED, and an EMRB.25 The TTA was staffed with two RNs per shift.
At the time of our inspection, the chief nurse executive (CNE) reported the current TTA
would be moved to the new diagnostic area, pending completion in June 2023. In the new
diagnostic area, the TTA would have five TTA beds and be in the same location as the RC
provider, mental health, laboratory, and dental facilities.
In addition, WSP had started training the medical staff on the new emergency medical
response (EMR) procedures during our on-site inspection. WSP planned to implement the
new EMR training throughout the institution in September 2023 after 80 percent of staff
were to have been trained. We were informed the dialysis contract nurses were not
involved in the new EMR training because they were not required to respond to alarms. If
the on-site dialysis area experienced an emergency, the dialysis nurses were instead
required to activate the alarm, and the WSP staff was expected to respond to the
emergency.
23 Deficiencies in TTA nursing documentation occurred in cases 1, 3, 5, and 20.
24 EMRRC deficiencies occurred in cases 1, 3, 5, 19, and 20.
25 An Omnicell is an automated medication dispensing machine.
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Recommendations
• Nursing leadership should determine the root cause of challenges that
prevent staff in completing thorough assessments, timely interventions, and
accurate documentation after an emergent event and implement remedial
measures as indicated.
• The EMRRC should thoroughly review emergency response events and
ensure the emergency response checklist review has identified the specific
findings or training issues.
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Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link
in high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Adequate (83.6%)
Case review found WSP performed poorly in health information management. Although
emergency documentation was fair, and providers usually endorsed diagnostic test results
timely, patient test results letters were often missing or had missing components. We
identified several clinically significant delayed and missing hospital and specialty reports.
In addition, on-site specialty progress notes were not endorsed, which led to delays in
patient care. After reviewing all aspects, the OIG case review rated the case review
component of this indicator inadequate.
Compliance testing showed WSP performed exceptionally well in scanning patient sick
call requests. Staff also performed well in retrieving, scanning, and endorsing hospital
records, and in scanning specialty documents. However, staff needed to improve in
labeling and scanning medical records into the correct patient files. Taking all results
into consideration, the OIG rated the compliance testing component of this indicator
adequate.
Case Review and Compliance Results
We reviewed 927 events and found 43 deficiencies related to HIM. Of these 43
deficiencies, 10 were significant.26
Hospital Discharge Reports
The quality of WSP’s retrieval of hospital discharge reports was mixed. Compliance
testing found WSP staff satisfactorily retrieved hospital discharge records and scanned
them into the EHRS timely (MIT 4.003, 84.2%). Frequently, WSP staff obtained complete
discharge summaries that primary care providers reviewed (MIT 4.005, 89.5%). OIG
clinicians reviewed nine hospital events and identified three HIM deficiencies involving
26 Deficiencies occurred in cases 1, 2, 9, 11–17, 19, 20, 52, and 53. Significant deficiencies occurred in cases 12,
16, 20, 52, and 53.
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poor retrieval and scanning of hospital records, one of which was considered significant.
The significant deficiency is below:
• In case 4, the patient was hospitalized for six days with a mandibular fracture
and brain bleed. During hospitalization, the patient developed an abnormal
heart rhythm. WSP staff did not scan Critical cardiology consultation
reports, cardiac test results, and a neurosurgery consultation report into the
EHRS until eight months later. Moreover, even once these important
documents were scanned in the EHRS, no providers endorsed any document.
We identified other deficiencies in the following cases:
• In case 20, the patient was seen in the hospital emergency room for dialysis
and having blood in the urine. WSP staff did not scan the hospital emergency
room discharge report until one and a half months later.
• Also in case 20, the patient returned from the hospital where a bladder mass
biopsy was performed. The preliminary hospital pathology report
documented the mass as an adenocarcinoma, with the final report pending.
WSP staff did not obtain the final pathology result report.
Specialty Reports
The institution’s management of specialty reports results also varied. Compliance testing
showed WSP performed very well in retrieving specialty reports (MIT 4.002, 90.0%).
Compliance testing also showed providers endorsed high-priority specialty reports
excellently (MIT 14.002, 100%). However, improvement was needed in endorsing medium-
priority and routine-priority specialty reports (MIT 14.005, 60.0% and MIT 14.008, 66.7%).
Our case review clinicians reviewed 97 specialty events, 44 of which required WSP’s staff
to obtain, scan, and endorse reports. Of those 44 events, the OIG identified 17
deficiencies related to HIM, eight of which were significant.
In addition, on-site specialty consultations were not endorsed.27 We discuss these
findings further in the Specialty Services indicator.
Diagnostic Reports
WSP’s performance with diagnostic reports was mixed. Both compliance testing and case
review found providers endorsed diagnostic studies timely; however, providers usually
did not communicate the results to the patient timely. Additionally, nurses often did not
notify providers of STAT laboratory test results, but providers performed well in
endorsing STAT results, once received.
Neither the ordering specialist nor an on-site provider endorsed specialty-ordered
diagnostic reports. Please refer to the Diagnostic Services indicator for more detailed
discussion about diagnostics.
27 Specialty health information management deficiencies occurred in cases 9, 12, 15,16, 20, 52, and 53.
Significant deficiencies occurred in cases 12, 20, 52, and 53.
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Urgent and Emergent Records
OIG clinicians reviewed 18 emergent care events and found nurses’ and providers’
documentation of events was fair. We identified errors in nursing documentation and
missing provider progress notes. Refer to the Emergency Services indicator for
additional information regarding emergency care documentation.
Scanning Performance
Scanning performance at WSP was poor. Compliance testing showed WSP needed
improvement in correctly scanning, labeling, and filing patient records (MIT 4.004,
54.2%). Case review clinicians identified 16 mislabeled, misfiled, or late records in eight
cases. Seven of the deficiencies were significant.28 These deficiencies are included above
in the Hospital Discharge Reports and Specialty Reports areas.
Clinician On-Site Inspection
OIG clinicians met with medical leadership, specialty staff, and HIM management to
discuss HIM processes, successes, and challenges. The HIM manager has been in her
position for over 17 years and is knowledgeable about processes and WSP. The manager
reported HIM was short-staffed with two vacant part-time positions, one health record
technician (HRT) II supervisor, and one office assistant on intermittent medical leave for
extended periods during the review period.
During the on-site discussion with us, HIM leadership and staff stated documents we had
identified as missing were in fact in the EHRS. However, we determined these documents
were not retrieved by WSP staff until after the OIG on-site letter cited the missing
documents.
At the on-site inspection, we learned the receipt of specialty reports is managed by the
specialty services office technician, as well as specialty and utilization management
nursing staff. Utilization management nursing has remote access to one of the local
hospital’s records, and specialty nursing has electronic access to some of the off-site
specialty reports. If remote access is unavailable, nursing staff requests the missing
specialty documentation. All retrieved documentation is then forwarded to HIM for
scanning and to providers for review and endorsement.
28 Deficiencies occurred in cases 4, 9, 14–16, 20, 52, and 53. Significant deficiencies occurred in cases 4, 52, and
53.
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Compliance Testing Results
Table 8. Health Information Management
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Table 9. Other Tests Related to Health Information Management
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Recommendations
• Medical leadership should ensure providers timely endorse all specialty
reports, including on-site specialty reports.
• Medical leadership should establish a mechanism to ensure either the
specialist or on-site primary care providers timely endorse all diagnostic
studies that were ordered by on-site specialty providers and are reported in
the medical record.
• Medical leadership should determine the root cause of challenges in sending
patient notification letters communicating laboratory tests and pathology
results, and should implement remedial measures as appropriate, including
ensuring clinic providers create patient notification letters with all four
elements required by CCHCS policy.
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Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection
control, sanitation procedures, medical supplies, equipment management, and
examination rooms. Inspectors also tested clinics’ performance in maintaining auditory
and visual privacy for clinical encounters. Compliance inspectors asked the institution’s
health care administrators to comment on their facility’s infrastructure and its ability to
support health care operations. The OIG rated this indicator solely on the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (43.2%)
In this cycle, multiple aspects of WSP’s performance in the health care environment were
poor. Medical supply storage areas both inside and outside the clinics contained expired
medical supplies, had compromised sterile medical supply packaging, or had medical
supplies stored directly on the floor. In addition, several areas of the examination rooms
were unsanitary; EMRB logs were missing staff verification or inventorying had not been
performed; several clinics did not meet the requirements for essential core medical
equipment and supplies; and staff did not regularly sanitize their hands before and after
examining patients. These factors resulted in an inadequate rating for this indicator.
Compliance Testing Results
Outdoor Waiting Areas
We examined outdoor patient waiting areas
(see Photo 1). Health care and custody staff
reported existing waiting areas had sufficient
seating capacity. Staff reported the outdoor
waiting area was only used when the indoor
waiting area was at capacity.
Indoor Waiting Areas
We also inspected indoor waiting areas
(see Photo 2, next page). Health care and custody
staff reported existing waiting areas contained
sufficient seating capacity. Depending on the
population, patients were either placed in the
clinic waiting area or held in individual modules
(see Photo 3, next page). During our inspection,
we did not observe overcrowding in any of the
clinics’ indoor waiting areas. Photo 1. Outdoor waiting area (photographed
on 2-16-23).
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Photo 2. Indoor waiting area
(photographed on 2-16-23).
Photo 3. Individual waiting modules
(photographed on 2-16-23).
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Clinic Environment
Of the 12 clinics we observed, 10 provided reasonable auditory privacy, appropriate
waiting areas, wheelchair accessibility, and nonexamination room workspace (MIT 5.109,
83.3%). In one clinic, the blood draw station was in close proximity to the patient waiting
area, which hindered auditory privacy. In the remaining clinic, the stations for checking
vital signs and drawing blood were in close proximity to the patient waiting area, which
similarly hindered auditory privacy.
Of the 12 clinics we observed, six contained appropriate space, configuration, supplies,
and equipment to allow their clinicians to perform proper clinical examinations (MIT
5.110, 50.0%). In the remaining six clinics, we observed one or more of the following
deficiencies: nursing staff providing services to multiple patients at the same time in the
examination room, which hindered auditory privacy (see Photo 4); torn covers on
examination tables, examination room chairs, and physical therapy equipment; an
examination room sink, a counter, and drawers in disrepair; unidentified examination
room supplies; and clinics with unsecured confidential medical records.
Photo 4. Multiple patients received service at the same time,
hindering auditory privacy (photographed on 2-15-23).
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Clinic Supplies
Only two of the 12 clinics
followed adequate medical supply
storage and management
protocols (MIT 5.107, 16.7%). We
found one or more of the
following deficiencies in 10
clinics: expired medical supplies
(see Photos 5 and 6), unidentified
or inaccurately labeled medical
supplies, compromised sterile
medical supply packaging,
cleaning materials stored with
medical supplies, personal items
belonging to staff stored with
medical supplies, and long-term
storage of food belonging to staff
in the medical supply storage
room (see Photo 7, next page).
Photo 5. Expired medical supplies dated
September 2022 (photographed on 2-16-23).
Photo 6. Expired medical supplies dated
May 2019 (photographed on 2-16-23).
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Photo 7. Staff members stored food on a long-term basis in the
medical supply storage room (photographed on 2-15-23).
Only five of the 12 clinics met requirements for essential core medical equipment and
supplies (MIT 5.108, 41.7%). The remaining seven clinics lacked medical supplies or
contained improperly calibrated or nonfunctioning equipment. The missing items
included examination table paper, lubricating jelly, tongue depressors, a peak flow meter
and tips, EMRBs, and a nebulization unit. In one clinic, staff had not properly calibrated
an automated vital signs machine and had no functioning thermometer. In another clinic,
the Snellen eye chart did not have a corresponding distance line marked on the floor or a
wall. In a third clinic, staff had not completed test log documentation for defibrillator
performance within the last 30 days. In addition, several clinic daily glucometer quality
control logs were either inaccurate or incomplete.
We examined EMRBs to determine whether they contained all essential items. We also
checked whether staff inspected the bags daily and inventoried them monthly. Only two
of the nine applicable EMRBs passed our test (MIT 5.111, 22.2%). We found one or both of
the following deficiencies with seven EMRBs: staff failed to ensure the EMRBs’
compartments were sealed and intact, or staff had not inventoried the EMRBs when seal
tags were replaced. In addition, the treatment carts in the TTA did not meet the
minimum inventory level at the time of our inspection.
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Medical Supply Management
None of the medical supply storage
areas located outside the medical
clinics stored medical supplies
adequately (MIT 5.106, zero). We found
medical supplies stored directly on the
floor (Photo 8) and compromised sterile
medical supply packaging. In addition,
the warehouse manager did not
maintain a temperature log for medical
supplies stored in the medical
warehouse that did provide
manufacturer’s temperature guidelines
(Photo 9, below).
Photo 8. Medical supplies stored directly on
the floor (photographed on 2-15-23).
According to the chief executive officer
(CEO), the institution did not have any
concerns about the medical supplies
process. Health care managers and medical
warehouse managers expressed no concerns
about either the medical supply chain or
their communication process with the
existing system.
Photo 9. Manufacturer’s temperature guidelines listed
on medical supplies were not followed
(photographed on 2-15-23).
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Infection Control and Sanitation
Staff appropriately cleaned, sanitized, and disinfected three of 12 clinics (MIT 5.101,
25.0%). In nine clinics, we found one or more of the following deficiencies: unmaintained
cleaning logs; unsanitary medical supply locations including storage shelves (Photo 10), a
medical supplies cart, a medical supplies bin, an examination room sink, an examination
room cabinet under the sink, and an examination room soap dispenser; and unsanitary
medical equipment including clinic gurneys and mattresses in the TTA. In three
locations, we found damaged and unsanitary examination room floors (Photo 11, next
page), and, in one of those three locations, biohazardous waste was not emptied the
previous day.
Photo 10. Unsanitary medical supply shelf (photographed on 2-14-23).
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Photo 11. Damaged and unsanitary examination room floor
(photographed on 2-14-23).
Staff in six of 12 clinics properly sterilized or disinfected medical equipment (MIT 5.102,
50.0%). In six clinics, we found one or both of the following deficiencies: staff did not
mention disinfecting the examination table as part of their daily start-up protocol, and
staff either did not have a good understanding of or did not follow the institution’s
sterilization cleaning protocols.
We found operating sinks and hand hygiene supplies in the examination rooms in seven
of 12 clinics (MIT 5.103, 58.3%). All 12 clinics had operating sinks; however, in five
clinics, the patient restrooms lacked either antiseptic soap or disposable hand towels.
We observed patient encounters in 11 of 12 applicable clinics. In seven clinics, staff did
not wash their hands before applying gloves or after examining their patients (MIT 5.104,
36.4%).
Health care staff in 11 of 12 clinics followed proper protocols to mitigate exposure to
blood-borne pathogens and contaminated waste (MIT 5.105, 91.7%). In one clinic, we
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found biohazardous waste stored in an unlabeled location, and the examination room was
missing a sharps container.
Physical Infrastructure
We gathered information to determine whether the institution’s physical infrastructure
was maintained in a manner that supported health care management’s ability to provide
timely and adequate health care. When we interviewed health care managers, they did not
have concerns about the facility’s infrastructure or its effect on the ability of staff to
provide adequate health care. At the time of inspection, the institution had three
infrastructure projects underway, which management believed would improve the
delivery of care at WSP:
• Project SP 1: Expansion of the A Yard clinic, which began in 2015, was
delayed due to the COVID-19 pandemic and was expected to have been
completed by March 2023.
• Project SP 6: Expansion of the TTA clinic, which had been completed, was
pending activation due to the delay of Construction Project SP 7. The TTA
was expected to have been activated by summer 2023.
• Project SP 7: A diagnostic and receiving and releasing (R&R) expansion and
modification project at WSP, which began in 2015, was delayed due to the
COVID-19 pandemic and was expected to have been completed by March
2023.
Despite the delay of the projects described above, the CEO did not believe this negatively
impacted the institution’s current ability to provide good patient care (MIT 5.999).
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Compliance Testing Results
Table 10. Health Care Environment
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Recommendations
• Executive leadership should consider performing random spot checks to
ensure clinics, medical storage rooms, and restrooms are cleaned properly
and timely.
• Medical leadership should remind staff to follow all applicable steps of the
universal hand hygiene procedure. Implementing random spot checks could
improve compliance.
• Executive leadership should consider performing random spot checks to
ensure medical supply storage areas, located outside the clinics, store
medical supplies adequately.
• Nursing leadership should direct each clinic nurse supervisor to review the
monthly EMRB and treatment cart logs to ensure the EMRBs and treatment
carts are regularly inventoried and sealed.
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Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions.
For newly arrived patients, our inspectors assessed the quality of health care screenings
and the continuity of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, inspectors checked
whether staff reviewed patient medical records and determined the patient’s need for
medical holds. They also assessed whether staff transferred patients with their medical
equipment and gave correct medications before patients left. In addition, our inspectors
evaluated the performance of staff in communicating vital health transfer information,
such as preexisting health conditions, pending appointments, tests, and specialty
referrals and confirmed whether 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 recommended
treatment plans, administered necessary medications, and scheduled appropriate follow-
up appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Adequate (78.3%)
Case review found WSP staff performed satisfactorily in this indicator. Nurses performed
well in completing initial assessments for newly arrived patients to WSP and completed
the disposition sections of the form thoroughly. Providers evaluated patients timely for
both newly arrived patients and patients returning from a hospitalization or emergency
room in the community. We also found the R&R nurses evaluated transfer-out patients
timely, completed transfer packages, and ensured adequate supplies of medications were
provided prior to patients transferring out of the institution. Case review did not identify
significant deficiencies for patients returning from off-site hospitalizations or emergency
rooms. However, we identified opportunities for improvement in nursing assessment,
interventions, and documentation. Factoring in all the information, OIG rated the case
review component of this indicator adequate.
Compared with Cycle 6, WSP’s compliance testing performance improved for this
indicator. Staff performed excellently in completing assessment and disposition section
of the screening process and in ensuring transfer packets for departing patients include
the required documents and medications. However, staff needed improvement in
completing initial health screening forms and in ensuring medication continuity for
newly transferred patients. Consequently, the OIG rated the compliance testing
component of this indicator adequate.
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Case Review and Compliance Testing Results
We reviewed 20 events in 14 cases in which patients transferred into or out of the
institution or returned from visits to an off-site hospital or an emergency room. We
identified 12 deficiencies, three of which were significant.29
Transfers In
The transfer-in process had mixed results for compliance testing and the clinician review.
The compliance team review revealed R&R nurses needed to improve in thoroughly
completing the initial health screening form (MIT 6.001, 52.0%); however, the nurses’
performance was excellent in completing the assessment and disposition section of the
form (MIT 6.002, 100%). OIG clinicians reviewed five events in three cases in which
patients transferred into the facility from other institutions, and found the R&R nurses
evaluated newly arrived patients adequately and ordered provider appointments within
required time frames.
The compliance team found WSP needed improvement in medication continuity at the
time of transfer (MIT 6.003, 61.1%). WSP also needed improvement in medication
continuity for patients who transferred within the institution (MIT 7.005, 56.0%). In
addition, WSP performed poorly in medication continuity for patients en route with
layovers at the institution (MIT 7.006, 40.0%). Our clinicians found two significant
deficiencies related to medication continuity.30 These deficiencies are discussed in the
Medication Management indicator.
Compliance testing found providers only intermittently saw newly arrived patients
within necessary time frames (MIT 1.002, 52.2%). In contrast, the case review clinicians
found providers timely saw newly arrived patients in the cases they reviewed.
Transfers Out
WSP’s transfer-out process was satisfactory. Our clinicians found the R&R nurses
evaluated patients timely, completed transfer packages, and ensured adequate supplies of
medications were provided prior to patients transferring out of the institution. OIG
clinicians reviewed four transfer-out cases and found one deficiency related to
documentation.31
Compliance testing found patients who transferred out of the institution always had their
medications and required documents (MIT 6.101, 100%).
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at a high risk
for lapses in care quality. Because these patients typically have experienced severe illness
or injury, they require more care and increase strain on the institution’s resources. In
addition, because these patients have complex medical issues, successful health
29 Deficiencies occurred in cases 20, 23, 24, 26, 52, and 54. Significant deficiencies occurred in cases 23, 24, and
52.
30 Medication continuity interruption occurred in cases 23 and 24.
31 A transfer-out deficiency occurred in case 26.
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information transfer is necessary for good quality care. Any transfer lapse can result in
serious consequences for these patients.
Compliance testing showed WSP needed improvement in providing follow-up
appointments within required time frames for patients returning from hospitalizations
and emergency room evaluations (MIT 1.007, 64.7%). This is discussed further in the
Access to Care indicator.
WSP performed satisfactorily in retrieving and scanning hospital records (MIT 4.003,
84.2%). Additionally, compliance testing found providers performed very well in
reviewing and endorsing documents timely (MIT 4.005, 89.5%)
Our clinicians reviewed eight hospitalizations and emergency care cases. We found
eight deficiencies, one of which was significant.32 Four deficiencies in three cases
related to nursing performance. We identified opportunities for improvement in
nursing performance in the following examples:
• In case 7, an RN evaluated the patient after returning from the community
emergency department for acute gastroenteritis. The nurse documented an
elevated pulse rate, but did not reassess the pulse.
• In case 20, nurses evaluated the patient, who was on hemodialysis and had a
dialysis shunt, after the patient returned from the emergency department and
again from the community hospital after an admission. Nurses did not assess
the patient’s dialysis shunt after either return.
• In case 52, the patient returned from the hospital, but nurses did not notify
the provider or the utilization management nurse the patient returned
without specialty consult reports for cardiology, ear, nose, and throat (ENT),
and neurosurgery, each of which occurred during hospitalization.
Compliance testing showed WSP performed poorly in medication continuity when
patients returned from hospitalization (MIT 7.003, 11.8%). Our clinicians identified
one deficiency, which was not considered significant.33
Clinician On-Site Inspection
During the on-site inspection, the clinicians were informed a dedicated transfer nurse
completed all the transfer packets due to the large volume of transfers. In addition, extra
staff assisted on days when large buses transported high numbers of incarcerated people
who were transferring out. R&R RNs were staffed on various shifts 24 hours each day.
Please see the Reception Center indicator for additional information.
32 Hospitalization and emergency care deficiencies occurred in cases 20, 52, and 53. A significant deficiency
occurred in case 52.
33 A hospital-return medication deficiency occurred in case 20.
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Compliance Testing Results
Table 11. Transfers
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Table 12. Other Tests Related to Transfers
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Recommendations
• Nursing leadership should determine the root cause of challenges that
prevent nurses in thoroughly completing the initial health screening process
including answering all questions and documenting an explanation for all
“Yes” answers before the patient is transferred to the housing unit and
implement remedial measures as appropriate.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in
administering prescription medications on time and without interruption. The inspectors
examined this process from the time a provider prescribed medication until the nurse
administered the medication to the patient. When rating this indicator, the OIG strongly
considered the compliance test results, which tested medication processes to a much
greater degree than case review testing. In addition to examining medication
administration, our compliance inspectors also tested many other processes, including
medication handling, storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (49.6%)
Case review found WSP had a mixed performance in this indicator. Staff performed well
in ensuring patients timely receive medications during transfer-in or transfer-out, while
in reception center, and after community hospitalizations. Staff also performed well in
timely providing newly prescribed medications. However, we identified several examples
in which chronic care and CTC medications were not provided timely or at all. Factoring
in all the information, the OIG rated the case review component of this indicator
adequate.
In compliance testing, WSP performed poorly overall. The institution showed good
performance in providing patients with newly prescribed medications as ordered and in
employing general security controls with narcotic medications in storage areas. However,
WSP needed to improve its medication continuity for patients with chronic care and
hospital discharge medications as well as for patients newly arrived from the reception
center, patients transferring within the institution, and patients temporarily housed in
WSP. On balance, the OIG rated the compliance testing component of this indicator
inadequate.
Case Review and Compliance Testing Results
We reviewed 107 events in 26 cases related to medications and found 23 medication
deficiencies, 10 of which were significant.34
New Medication Prescriptions
Compliance testing found 92.0 percent of new medications were available or
administered timely (MIT 7.002). Our clinicians found two deficiencies, one of which was
34 Medication deficiencies occurred in cases 2, 9, 12, 15, 19, 20, 21, 23, 24, 52, 53, and 54. Significant deficiencies
occurred in cases 20, 21, 23, 24, 53, and 54.
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significant.35 The significant deficiency is further detailed in the Reception Center
indicator.
Chronic Medication Continuity
During this review period, WSP performed poorly in chronic medication continuity.
Compliance testing showed patients sporadically received their chronic care medications
within required time frames (MIT 7.001, 26.3%). In these samples, patients did not receive
medications timely for high blood pressure, high cholesterol, diabetes, and seizures. Case
review found several cases in which chronic care medications were not provided timely or
were not provided at all, 36 as described in the following examples:
• In case 9, during September 2022, the patient received two 30-day supplies of
a KOP blood pressure medication, two days apart.37
• In case 20, during November 2022, the dialysis patient did not receive an
important potassium-lowering medication several times on the nondialysis
days as ordered.38 This could have potentially resulted in elevated potassium
levels, which would have increased the medical risk for this dialysis patient.
• In case 21, the patient was receiving a medication to treat chronic hepatitis
C; however, the patient did not receive the medication from June 2022 to
September 2022 due to the medication not being available.
Hospital Discharge Medications
Compliance testing showed staff rarely provided patients with their discharge
medications on return from an off-site hospitalization or emergency room evaluations
(MIT 7.003, 11.8%). In these test samples, nursing staff did not provide a reason for the
patient refusing medications, and staff did not timely provide medications to treat
infections, high blood pressure, cholesterol, narcotic dependence, seizures, or to decrease
calcium levels. In contrast, our clinicians found staff performed well in ensuring patients
received their medications after a community hospital evaluation. Our clinicians
identified one deficiency, which was not considered significant.39
Specialized Medical Housing Medications
Compliance testing revealed patients admitted to the CTC occasionally received their
medications timely (MIT 13.003, 40.0%). In two samples, patients received diabetic and
seizure medications one day late. In other samples, the pharmacy did not timely fill and
dispense medications including those for high blood pressure, cholesterol, pain, and
35 New medications were not received timely in cases 15 and 20.
36 Chronic care medications were not received timely occurred in cases 2, 9, 12, 20, 21, 23, 24, and 52. Significant
deficiencies occurred in case 20, 21, 23, and 24.
37 KOP means “keep on person” and refers to medications in which a patient can keep and self-administer
according to the directions provided.
38 The mediation was sodium zirconium cyclosilicate (Lokelma).
39 A hospital discharge medication deficiency occurred in case 20.
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blood clots. Our clinicians identified five deficiencies related to medication management;
three were considered significant.40
• In case 52, during September 2022, the patient did not receive two doses of a
blood pressure medication (metoprolol). Furthermore, one day in October,
the nurse administered this medication three times to the patient instead of
two times.
• In case 53, the patient with rectal cancer and severe diarrhea was ordered to
have intravenous (IV) fluids throughout the review period. However, the CTC
nurses did not administer the IV fluids as ordered for October and December
2022.
• In case 54, during October 2022, the CTC nurses did not consistently check
the diabetic patient’s blood sugar before administering the evening dose of
insulin. In addition, during October 2022, the patient’s blood sugar readings
were intermittently at high levels, and nursing staff did not notify the
provider of the need for further management of these high blood sugar levels.
Transfer Medications
For transfer medications, WSP needed to improve with medication continuity at the time
of transfer (MIT 6.003, 61.1%) and for patients who transferred within the institution
(MIT 7.005, 56.0%). WSP performed poorly for patients en route with layovers at the
institution for concerns related to medication continuity (MIT 7.006, 40.0%). Compliance
testing revealed patients who transferred in from county jails only sporadically received
medications timely as ordered (MIT 7.004, 33.3%). In three of the samples, patients
received their medications later than the ordered start time. Our clinicians found two
significant deficiencies related to transfer-in medication continuity41 as seen in the two
cases below:
• In case 23, the patient with heart disease did not receive the KOP aspirin for a
month after arriving to the institution.
• In case 24, the transfer-in patient had a duplication of medication orders to
treat cholesterol, urinary retention, and Parkinson’s disease. Subsequently,
the patient received double the evening doses for these conditions.
OIG clinicians found one significant deficiency related to medication continuity as it
related to a lapse in the care of patients arriving from the county jail: a dialysis
patient did not receive the following medications as ordered: antibiotic, pain, and
medication to lower phosphorus levels.
40 Deficiencies occurred cases 52, 53, and 54. Significant deficiencies occurred in cases 53 and 54.
41 Transfer medication deficiencies occurred in cases 23 and 24. Both deficiencies were significant.
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Medication Administration
Staff performed very well in ensuring TB medications were administered timely (MIT
9.001, 88.0%). Compliance testing also found nurses sometimes monitored patients taking
TB medications as required by policy (MIT 9.002, 72.0%).
Clinician On-Site Inspection
During the on-site inspection, OIG clinicians met with the pharmacist-in-charge (PIC)
and the CNE to discuss specific medication-related deficiencies. They informed us they
were receiving approximately 400 RC patients a week and could provide medications in a
timely way with the current processes implemented. The RC area had an Omnicell, and
an RN and an RC provider reviewed medications to prevent lapses in medication
continuity. The PIC reported no general obstacles with providing medication services.
During after-hours, nursing staff could obtain medications from the Omnicell or clinic
stock, or contact the on-call pharmacist as needed. The institution had recently added an
outside vendor pharmacy service to help with providing after-hours medications as
needed. The PIC reported the main issues with medication continuity for patients
arriving from the county jails, or discharged from a higher level of care, were high cost or
unusual medications that took more time to procure. The PIC also reported ISUDT had
greatly affected pharmacy services; as of December 31, 2022, WSP had 428 ISUDT
patients and 503 active ISUDT medication orders.
OIG clinicians toured the medication administration areas and found nurses were
knowledgeable concerning the medication administration process. Medication
administration areas were clean and organized, and they did not have a backlog of KOP
medications to administer. Medication nurses attended huddles and discussed
medication compliance and nonadherence, expiring medications, and medication
continuity for patients transferring to the care team, those new to the institution, or
those who were returning from the hospital.
Compliance Testing Results
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in eight of nine clinic
and medication line locations (MIT 7.101, 88.9%). In one location, narcotic medications
were not properly secured or stored during transport as required by CCHCS policy.
WSP appropriately secured and stored nonnarcotic medications in eight of 11 clinic and
medication line locations (MIT 7.102, 72.7%). In three locations, we observed one or both
of the following deficiencies: nurses did not maintain unissued medication in its original
labeled packaging; the medication room lacked a clearly labeled designated area for
medications to be returned to the pharmacy; and a daily security check treatment cart log
entry was incomplete.
Staff kept medications protected from physical, chemical, and temperature
contamination in only two of the 11 clinic and medication line locations (MIT 7.103,
18.2%). In nine locations, we found one or more of the following deficiencies: staff did not
consistently record the room temperatures; staff did not consistently record the
refrigerator temperatures or keep the temperature within the acceptable range; staff did
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not store oral and topical medications separately; and the medication refrigerator was
unsanitary.
Staff successfully stored valid, unexpired medications in nine of the 11 applicable
medication line locations (MIT 7.104, 81.8%). In two locations, nurses did not label the
multiple-use medications as required by CCHCS policy.
Nurses exercised proper hand hygiene and contamination control protocols in three of
seven locations (MIT 7.105, 42.9%). In four locations, some nurses neglected to wash or
sanitize their hands before donning gloves or before each subsequent regloving.
Staff in five of seven medication preparation and administration areas demonstrated
appropriate administrative controls and protocols (MIT 7.106, 71.4%). In two locations,
medication nurses did not describe the process they followed when reconciling newly
received medication and the medication administration record (MAR) against the
corresponding physicians’ orders.
Staff in three of seven medication areas used appropriate administrative controls and
protocols when distributing medications to their patients (MIT 7.107, 42.9%). In four
locations, we observed one or more of the following deficiencies: medication nurses did
not distribute medications to patients within the time frame of one hour before or one
hour after the normal distribution time; a medication nurse did not consistently observe
patients while they swallowed direct observation therapy medications and did not
consistently verify patients’ identification prior to administration; and medication nurses
did not follow the CCHCS care guide when administering Suboxone medication, that is,
medication nurses did not provide counseling for 30 seconds to ensure the Suboxone
medication adhered to the patient’s mouth.
Pharmacy Protocols
WSP always followed general security, organization, and cleanliness management
protocols in its pharmacy (MIT 7.108, 100%). However, in its pharmacy, staff did not
properly store nonrefrigerated medication. We also found medication stored in an
inaccurately labeled container. As a result, the institution scored zero for this test (MIT
7.109).
The institution properly stored refrigerated or frozen medications in the pharmacy (MIT
7.110, 100%).
The PIC did not thoroughly review monthly inventories of controlled substances in the
institution’s clinic and medication storage locations. Specifically, the pharmacist present
at the time of the medication area inspection did not correctly complete the inspection
checklist (CDCR form 7477) in several medication areas. These errors resulted in a score
of zero for this test (MIT 7.111).
We examined 20 medication error reports. The PIC timely or correctly processed only
three of these 20 reports (MIT 7.112, 15.0%). For 17 reports, we found one or more of the
following deficiencies: the PIC did not provide a medication error follow-up review form,
the PIC did not document the patient had been notified of a medication error, and the
PIC did not document the recommended changes to correct the medication error from
occurring in the future.
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Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors
also followed up on any significant medication errors found during compliance testing.
We did not score this test; we provide these results for informational purposes only. At
WSP, the OIG did not find any applicable medication errors (MIT 7.998).
The OIG interviewed patients in restricted housing units to determine whether they had
immediate access to their prescribed asthma rescue inhalers or nitroglycerin
medications. All 10 applicable patients interviewed indicated they had access to their
rescue medications (MIT 7.999).
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Compliance Testing Results
Table 13. Medication Management
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Table 14. Other Tests Related to Medication Management
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Recommendations
• The institution should consider developing and implementing measures to
ensure staff timely make available and administer medications to patients
and document administering medications in the EHRS, as described in
CCHCS policy and procedures.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
out patients quickly. The OIG rated this indicator solely according to the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Adequate (78.5%)
WSP had a mixed performance in this indicator. The institution performed well in
administering TB medications, screening patients annually for TB, offering patients an
influenza vaccine for the most recent influenza season, and offering colorectal cancer
screening for patients from ages 45 through 75. However, WSP only intermittently
monitored patients taking prescribed TB medications, rarely offered required
immunizations to chronic care patients, and intermittently transferred out patients who
had the highest risk of coccidioidomycosis (Valley Fever) infection to an appropriate
facility. Overall, the OIG rated this indicator adequate.
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Compliance Testing Results
Table 15. Preventive Services
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Recommendations
• Nursing leadership should analyze the challenges to ensuring
nursing staff monitor and address symptoms of patients receiving TB
medications according to CCHCS guidelines and take necessary
remedial measures.
• Nursing leadership should analyze the challenges in ensuring patients at the
highest risk of coccidioidomycosis (Valley Fever) are monitored and
transferred in a timely manner.
• Medical and nursing leadership should analyze the challenges
related to the untimely provision of preventive vaccines to chronic
care patients and implement remedial measures as appropriate.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care delivered by the
institution’s nurses, including registered nurses (RN), licensed vocational nurses (LVN),
psychiatric technicians (PT), certified nursing assistants (CNA), and medical assistants
(MA). Our clinicians evaluated nurses’ performance in making timely and appropriate
assessments and interventions. We also evaluated the institution’s nurses’ documentation
for accuracy and thoroughness. Clinicians reviewed nursing performance across many
clinical settings and processes, including sick call, outpatient care, care coordination and
management, emergency services, specialized medical housing, hospitalizations,
transfers, specialty services, and medication management. The OIG assessed nursing care
through case review only and performed no compliance testing for this indicator.
When summarizing overall nursing performance, our clinicians understand nurses
perform numerous aspects of medical care. As such, specific nursing quality issues are
discussed in other indicators, such as Emergency Services, Specialty Services, and
Specialized Medical Housing.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
WSP’s overall nursing performance was poor. Case review found nurses frequently
performed incomplete nursing assessments in the outpatient and specialized medical
housing settings. In addition, we identified areas for improvement with untimely and
inappropriate nursing interventions. However, nurses performed well in caring for
patients in the RC, patients returning from the hospital, and patients returning from off-
site specialty appointments. Nonetheless, considering all these factors, OIG rated this
indicator inadequate.
Case Review Results
We reviewed 206 nursing encounters in 51 cases. Of the nursing encounters we reviewed,
125 occurred in the outpatient setting, and 71 were sick call requests. We identified 77
nursing performance deficiencies, 19 of which were significant.42
Outpatient Nursing Assessment and Interventions
A critical component of nursing care is the quality of nursing assessment, which includes
both subjective (patient interviews) and objective (observation and examination)
elements. Our clinicians identified 48 outpatient nursing deficiencies, 14 of which were
considered significant.43 These deficiencies included nurses in the medical clinics did not
42 Nursing performance deficiencies occurred in cases 1-3, 5, 7, 10, 11, 13–15, 18–21, 24, 26, 32, 34, 39, 42, 43, 45–
49, and 52–54. Significant deficiencies occurred in cases 5, 7, 10, 14, 20, 32, 39, and 47.
43 Outpatient nursing deficiencies occurred in cases 1, 2, 7, 10, 11, 13–15, 18–21, 32, 34, 39, 42, 43, and 45–49.
Significant deficiencies occurred in cases 7, 10, 14, 20, 32, 39, and 47.
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always properly triage a symptomatic sick call that required a same-day evaluation, and
nurses frequently performed incomplete nursing assessments. Examples of incomplete
assessments, interventions, and delays in same-day sick call evaluations are listed below:
• In case 7, the patient submitted a sick call request for pain in the groin on
the right side and in the right leg with concerns of possible infection or
kidney stone. In addition, during the face-to-face encounter, the patient
reported pain in both the lower back and the right-upper leg. The sick call
nurse did not inquire concerning the time of onset and the duration of
symptoms, review medication compliance, perform a skin assessment, or
assess urinary signs and symptoms. In addition, the nurse did not document
if the provider was notified of the lower-back symptoms or inquire if any
further laboratory work-up was needed.
• In case 14, the patient complained of abdominal pain, vomiting, headache,
dizziness, and orange-colored urine. The sick call nurse did not perform a
complete abdominal assessment, which includes listening to bowel sounds
and inquiring about the last bowel movement, the stool color, and vomiting.
In addition, the nurse did not assess the skin or the urinary system for any
signs and symptoms. Furthermore, the nurse reassessed the patient for
abdominal pain one week later, and the patient continued to have severe
abdominal pain and tenderness. However, the nurse did not consult with the
provider for a further plan of care.
• In case 20, nurses evaluated the patient suspected of having bladder cancer,
who arrived to WSP from the county jail. The patient submitted multiple sick
call requests to see the urologist for his bladder cancer and complained of
blood in the urine for several months, as well as diarrhea. The patient also
requested a renewal of an antibiotic (Amoxicillin), which the patient
previously had received after a knee infection, and had been informed by the
outside community hospital provider that he would need for the rest of his
life. The sick call nurse scheduled the patient to follow-up with the provider
in 14 days. In addition, the nurse ordered a 14-day follow-up with a provider
instead of consulting with the provider on the patient’s report of blood in the
urine and for the antibiotic renewal. During multiple sick call nurse
evaluations for diarrhea and blood in the urine, the nurse frequently did not
assess the abdomen, inquire on the frequency of the diarrhea episodes,
inquire on the frequency and color of the blood in the urine, or notify the
provider when the antidiarrheal medication was not effective.
• In case 39, the patient with congestive heart failure, hypertension, diabetes,
hyperlipidemia, and end-stage renal disease on hemodialysis submitted a
sick call request for excruciating daily leg cramps. The sick call nurse did not
schedule a same day appointment for the urgent symptom for possible blood
clots. In addition, the nurse did not listen to the heart and lung sounds or
obtain subjective information concerning the aggravating and relieving
factors of the cramps during the face-to-face evaluation.
• In case 47, the sick call nurse did not schedule a same-day appointment for
the patient reporting vomiting blood, who was at risk of internal bleeding
and increased blood loss. The sick call nurse evaluated the patient the next
day, and the patient reported having vomited blood for a couple of weeks and
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of being constipated. However, the nurse did not do a complete assessment
of the abdomen and skin, nor obtain objective information on the vomiting
frequency and description of the vomit, such as whether it looked like coffee
grounds or had bright red blood in it. In addition, the nurse did not consult
with the provider for a further plan of care.
Outpatient Nursing Documentation
Complete and accurate nursing documentation is an essential component of patient care.
Without proper documentation, health care staff can overlook changes in patients’
conditions. Nurses generally documented care appropriately.
Case Management
OIG clinicians reviewed five cases in which patients were evaluated by a care manager or
care coordinator.44 Case review identified five deficiencies in evaluating patients for care
management and care coordinator appointments, none of which was significant.45 The
following are examples:
• In case 14, the care management nurse evaluated the patient for hypertension
and ordered blood pressure checks weekly for one month. However, the
nurse did not schedule an appointment for a blood pressure follow-up or
contact the provider with the blood pressure reading.
• In case 20, nursing staff intermittently completed vital signs checks on the
patient after dialysis. In addition, on several occasions, the patient’s pulse
was low, and nurses did not recheck the pulse. Last, nursing staff only
intermittently completed a full set of vital signs checks to include the
respirations, the pulse, and the temperature.
Emergency Services
OIG clinicians reviewed 18 urgent or emergent events. Nurses generally responded
timely to emergent events. However, their assessments, interventions, and
documentation showed room for improvement, which we detail further in the Emergency
Services indicator.
Hospital Returns
We reviewed nine nursing events in eight cases that involved returns from off-site
hospitals or emergency rooms. The clinicians identified four deficiencies, none of which
was significant.46 Nurses generally performed good nursing assessments, interventions,
and documentation. Please refer to the Transfers indicator for further details.
44 Patients were evaluated by the care manager or care coordinator in cases 12–14, 17, and 20.
45 Deficiencies occurred in cases 14 and 20, none of which was significant.
46 Deficiencies occurred in cases 20, 52, and 53.
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Transfers
We reviewed seven cases involving transfer-in and transfer-out processes. The
compliance team found the R&R nurses did not always thoroughly complete the initial
health screening form; however, nurses did well in completing the assessment and
disposition section of the form. WSP also performed poorly with medication continuity at
the time of transfer for both patients who transferred within the institution and patients
en route with layovers at the institution. Please refer to the Transfers indicator for
further details.
Reception Center
OIG clinicians reviewed nine cases with patients who arrived at the RC and found two
nursing deficiencies, one of which was significant.47 Compliance testing found nurses
performed well in completing the initial health screening forms thoroughly, timely
signing and completing the assessment and disposition portion of the health screening
form. Please refer to the Reception Center Arrivals indicator for further details.
Specialized Medical Housing
We reviewed three CTC cases with a total of 16 nursing events. We identified 10 nursing
deficiencies, none of which was significant.48 Nurses generally performed timely
assessments and frequently evaluated patients. However, we identified opportunities for
improvement in completing thorough assessments and interventions. For more specific
details, please refer to the Specialized Medical Housing indicator.
Specialty Services
We reviewed 20 events in 10 cases in which patients returned from an off-site specialist
appointment. We identified two deficiencies, one of which was significant.49 Nursing
staff appropriately assessed patients, reviewed specialist findings and recommendations,
and consulted with the provider. Please refer to the Specialty Services indicator for more
information.
Medication Management
OIG clinicians examined 107 events involving medication management and found 23
medication deficiencies, 10 of which were significant.50 Both case review and compliance
scores showed poor performance in specialized medical housing and chronic care
medication continuity. In contrast, WSP had mixed results for medication continuity for
patients returning from the hospital or transferring, or for RC patients. Please refer to the
Medication Management indicator for additional details.
47 Deficiencies occurred in cases 2 and 20. A significant deficiency occurred in case 20.
48 CTC nursing performance deficiencies occurred five times in case 54, four times in case 52, and once in case
53. There were no significant deficiencies.
49 Deficiencies occurred in cases 20 and 53. A significant deficiency occurred in case 20.
50 Medication deficiencies occurred in cases 2, 9, 12, 15, 19–21, 23, 24, and 25. Significant deficiencies occurred
in cases 20, 21, 23, 24, 53, and 54.
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Clinician On-Site Inspection
Our clinicians spoke with nurse supervisors and nurses in the TTA, CTC, R&R, specialty
services, outpatient clinics, and medication administration areas. We observed huddles
were well attended by the care team, were organized, and pertinent information was
reported. We also attended the CTC huddle that included the utilization nurse and the
mental health provider.
On the sensitive needs yard, the clinic nurses reported evaluating approximately 30
patients per day, and staff reported no appointment backlog. This yard had two RNs and
one RN floater who worked in multiple areas. This area had a dormitory setting with
approximately 800 patients. The senior registered nurse (SRN) II reported voluntary
overtime was provided for the RNs on the weekends to help prevent sick call backlogs
due to the large volume of sick calls on Fridays and on the weekends. The LVNs perform
daily wound care, and the RNs provide weekly wound care evaluations. During the
clinician case review period, we had no wound care sample cases to evaluate. Staff
reported the main priority was sick call evaluations. Care management issues, such as
laboratory orders and vaccinations, were addressed during population management
meetings.
We met with nursing leadership, who addressed our findings and acknowledged
opportunities for quality improvement. During our case review period, we found COVID-
19 quarantine rounding orders were notated in the EHRS; however, we found no
corresponding nursing rounding documentation. Nursing leadership provided a CCHCS
COVID-19 memorandum that allowed WSP to export and print a paper list of patients
who were on COVID-19 quarantine from the COVID Monitoring Registry. Nurses no
longer needed to document these quarantine rounds in the EHRS unless the patient was
symptomatic. Nursing leadership provided us with the paper list of patients on COVID-
19 quarantine about whom we had questions.
Nursing leadership reported SRN IIs were responsible for conducting 10 sick call audits
each month per nursing staff. In addition, SRN IIs audited the medication administration
areas. WSP informed us clinic RNs acted as care managers, and clinic LVNs performed
care coordinator duties, which included providing vaccinations, conducting vital signs
checks, and distributing durable medical equipment and diabetic supplies. Clinic RNs
explained that most of the care management was completed during population
management meetings by discussing any significant cases and ordering any needed
appointments or laboratory tests.
At the time of the on-site inspection, WSP informed us they had a nine percent nursing
vacancy, with most of the vacancies being RNs. The CNE reported challenges with
staffing were due to uncompetitive salaries compared with salaries offered to nurses in
the community. Staff had been attending hiring events at job fairs and local colleges. In
addition, students from San Joaquin Valley College performed clinical rounding at WSP
with medical assistants (MAs) and LVNs, which gave WSP an opportunity to recruit them
as well, for the future.
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Recommendations
• Nursing leadership should analyze the challenges to nurses performing
thorough, detailed assessments and interventions during patients’
appointments and reenforce the audits already implemented.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of care delivered by the
institution’s providers: physicians, physician assistants, and nurse practitioners. Our
clinicians assessed the institution’s providers’ performance in evaluating, diagnosing,
and managing their patients properly. We examined provider performance across several
clinical settings and programs, including sick call, emergency services, outpatient care,
chronic care, specialty services, intake, transfers, hospitalizations, and specialized
medical housing. We assessed provider care through case review only and performed no
compliance testing for this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Not Applicable
WSP providers performed poorly overall in delivering care. Although providers
performed satisfactorily in assessments and decision making, documentation, chronic
care, and emergency services, we identified lack of follow-up, inappropriate time frame
orders, poor differential diagnosis, and incomplete history taking. We also found
instances in which poor record review and possible superficial provider care may have
contributed to either patient harm or missed treatment opportunities. After careful
consideration of all factors, the OIG rated this indicator inadequate.
Case Review Results
OIG clinicians reviewed 120 medical provider encounters and identified 116 deficiencies,
32 of which were significant.51 In addition, our clinicians examined the quality of care in
18 comprehensive case reviews. Of these 18 cases, we rated 14 adequate and four
inadequate.
Outpatient Assessment and Decision-Making
OIG clinicians found many assessment and decision-making deficiencies. We frequently
found incomplete history-taking, poor differential diagnosis and assessments, a lack of
follow-up, and orders for inappropriate time frames. Examples include the following
cases:
• In case 7, during the initial patient health assessment, the patient with
significant cardiac risk factors complained of indigestion symptoms. The
provider did not consider the patient’s symptoms could have been from
cardiac causes and did not perform an appropriate diagnostic examination.
51 Deficiencies occurred in cases 1, 2, 7, 9–22, and 52–54. Significant deficiencies occurred in cases 7, 10, 13–16,
20–21, 52, and 56.
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Unfortunately, the patient died of a heart attack approximately one month
later.
• In case 10, the RN contacted the provider about a diabetic patient who had
pain in the left side with urination, which could indicate a kidney stone or
kidney infection. The provider ordered a laboratory urinalysis to be done in
seven days. Since urine dipstick testing was not immediately available, the
urinalysis should have been ordered STAT or same day. The provider also
ordered a follow-up appointment in 14 days, but the patient should have been
assessed more urgently.
• In case 16, the provider saw the patient who had an acute significant drop in
red blood cells, which can be a sign of internal bleeding. The provider did not
consider gastroenterological causes or internal bleeding in the differential
diagnosis and did not perform an appropriate diagnostic examination.
• In case 20, the provider who performed the initial history and physical did
not address the patient’s documented history of suspected bladder cancer
and did not order a follow-up to ensure this potential condition was
addressed. Another provider then ordered the chronic care appointment to
address the bladder cancer and other unaddressed chronic medical
conditions; however, that provider did not address the bladder cancer,
delaying care to the patient.
Outpatient and RC Review of Records
As an RC, review of medical records is especially important. OIG clinicians found
providers did not always carefully review medical records. We identified 13 deficiencies
related to poor medical-record review, four of which were considered significant.52 In two
of the nine RC cases reviewed, we determined poor record review and possible superficial
care by providers may have either contributed to patient harm or resulted in persistently
missed medical issues throughout the review period. Examples of significant deficiencies
include those in the following cases:
• In case 7, the patient’s intake laboratory test results indicated a positive test
result for tuberculosis.53 Providers did not address this abnormal laboratory
result during the review period.
• Also in case 7, the provider performed the initial patient health care
assessment. However, the provider did not review the patient’s medical
record from previous incarcerations, which included diagnoses of
dyslipidemia and partial blockage of the main arteries going to the brain.54
Because the provider missed these diagnoses, the provider did not consider
ordering aspirin or other treatment for cardiovascular disease.
Unfortunately, the patient died a few weeks later of a heart attack.
52 Deficiencies occurred in cases 7, 12, 14, 15, 17, 19, 20, 22, 53, and 54. Significant deficiencies occurred in cases
7,15, 20, and 54.
53 QuantiFERON-TB Gold Plus is a test used to detect tuberculosis.
54 Dyslipidemia is a condition with abnormal levels of blood lipids, such as cholesterol and trigylcerides.
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• In case 20, the patient’s transfer documentation from the county jail showed
the patient had chronic heart failure, coronary artery disease, glaucoma, and
a history of gastric bypass, in addition to multiple other medical conditions.
Providers did not acknowledge or address these conditions in either the
medical documentation or the provider assessments and plans during the six-
month review period.
Emergency Care
Providers made appropriate triage decisions when patients arrived at the TTA for
emergency treatment. Although providers were available for consultation with TTA
nursing staff, we identified four minor deficiencies related to poor or lack of provider
emergency documentation.55
Chronic Care
Providers need to improve in managing patients’ chronic medical conditions. Several
significant deficiencies in chronic care occurred because providers had not adequately
reviewed the patient’s medical record, were unaware of medical problems that required
follow-up, or made poor assessments regarding the chronic state of certain illnesses.
Examples include the following cases:
• In case 12, the provider sent the patient an ultrasound results letter stating
his results were normal or unchanged; however, no prior ultrasound had been
completed, and the new results indicated the patient had cirrhosis (liver
disease), which was not normal and required both a follow-up and avoidance
of liver toxic substances. The provider did not discuss the diagnosis or the
need for liver care with the patient and did not develop an appropriate
assessment and plan.
• In case 15, throughout the review period and for over one year, the primary
care provider did not address the high-risk patient’s lung condition that
required inhaled medications or the chronic use of blood thinners in either
progress notes or assessments and plans. The patient was on a lung
medication without a documented medical indication. This high-risk patient
did not have a chronic care appointment for at least eight months, and
providers addressed only acute problems during this period.
• In case 16, the provider ordered the patient to have a chronic care
appointment combined with a follow-up after a transplant surgeon evaluated
the patient. At the appointment, the provider did not address the high-risk
patient’s chronic medical conditions.
Outpatient and CTC Documentation Quality
As it had been in the Cycle 6 inspection, poor documentation continued to be a problem
at WSP in Cycle 7. OIG clinicians identified over 50 deficiencies that included missing
provider progress notes, incomplete documentation, cloned progress notes with
inaccurate assessments and plans, and providers not updating patients’ lists of
55 Emergency documentation deficiencies occurred in cases 19 and 20. None was significant.
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concerns.56 In many instances, it was very difficult to determine what history the provider
had obtained and what care was provided to the patient. The CTC provider, who is
responsible for some of the most ill patients, frequently cloned progress notes with
incorrect and outdated information. Other providers frequently made medical decisions
without documenting any medical reasoning, or the documentation was missing
important components such as a review of systems or physical examinations. Examples of
documentation deficiencies were discussed in the following cases:
• In case 14, the provider saw the patient whose CT scan indicated the patient
had cirrhosis (liver disease). The provider did not add cirrhosis to the
patient’s problem list in the patient’s electronic medical records to ensure
both appropriate follow-up treatment and the avoidance of liver-toxic
substances or medications, did not advise the patient of the presence of
cirrhosis, and did not develop an appropriate assessment and plan.
• In case 15, the RN contacted the provider about a patient who fell on the way
to hemodialysis and had significant ankle pain. The provider ordered an X-
ray and pain medication, and reviewed and endorsed the X-ray, but did not
document an assessment or a plan for the patient.
• In case 54, the specialized medical housing provider had previously increased
the patient’s long-acting insulin medication; however, in the next two weeks,
the provider documented in all the progress notes to increase the insulin,
which already had been done. In addition, the provider documented an
incorrect assessment and plan for high blood pressure, repeating “start low
dose amlodipine” in each progress note for six weeks after that medication
had already been started.
Provider Continuity
The cases we reviewed showed most patients initially saw several providers for care due
to the intake nature of an RC. One provider would see the patient for a focused health
care assessment prior to transfer to the yard, and once transferred, provider continuity
was generally good.
Clinician On-Site Inspection
OIG clinicians met with medical leadership and providers to discuss challenges,
achievements, and deficiencies. As an RC, WSP had developed a specialized system called
“Diagnostics” whereby new departmental patients, approximately 400 arriving per week,
could be assessed for dental, mental health, and medical screenings. Nurses performed
the initial health assessments on the day of arrival; ordered intake screening laboratory
work; and scheduled the provider, mental health, dental, and RN follow-up appointments
based on patient acuity level. Providers were required by policy to perform an RC-focused
health care assessment for each newly arrived patient within five business days; however,
we identified delays. Medical leadership, scheduling staff, and providers reported
providers did not see the newly arrived patients until they were out of 10- to 14-day
56 Documentation deficiencies occurred in 7, 9, 11, 13–15, 17, 18, 20, 21, 52, and 54.
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quarantine. Nurses, however, performed their initial health assessments within required
time frames.
In the case reviews, we found different levels of care from providers regarding the
required provider RC-focused health care assessment. CCHCS RC policies detail the
requirements.57 Some providers only completed durable medical equipment requirements
and did cursory reviews. Providers frequently did not complete physical exams and often
did not address chronic medical conditions. At our on-site visit, we received conflicting
responses from different providers about what they believed they were required to do for
an RC-focused health care assessment. One provider stated they only order durable
medical equipment; several mentioned they do not handle any chronic medical
conditions regardless of severity; others stated they only handle urgent or emergent
issues. We also found providers did not thoroughly address chronic care issues and
sometimes did not timely order the follow-up appointment to address them. OIG
clinicians found this particularly concerning because yard providers stated they relied
heavily on the information from the provider RC-focused health care assessments.
We found generally poor provider documentation throughout the institution and
extensive progress note cloning in the CTC. HIM management stated cloned progress
notes were not acceptable, but providers were permitted to insert personalized saved
phrases into their documentation. HIM reported their department did monitor for cloned
progress notes in the CTC and sent a Physician Deficiency Detailed Report to the CME
and chief physician and surgeon (CP&S) when cloned progress notes were found. HIM
staff sent reminders to providers and to the CP&S about this report via email. WSP did
not provide our clinicians with copies of the Physician Deficiency Detailed Report or
email follow-ups to support whether this process occurred or was effective.
The WSP CME was very highly regarded by those providers we interviewed, as was the
CP&S. The CP&S was relatively new to this position and was not available to speak with
during our inspection. All providers felt supported by both the CME and the CP&S.
Providers felt they had good peer rapport and a good working group. Some long-term
physicians had recently retired. The CME acknowledged difficulty recruiting new
providers because other surrounding institutions offered a 15 percent pay differential,
which was not authorized at WSP. At the time of our inspection, CCHCS telemedicine
providers and several registry providers were filling the positions. Some registry
providers traveled extensive distances for their daily work, but stated they believed the
travel was worth it because they enjoyed the management and the work at WSP.
We discussed the poor documentation with medical leadership. When we asked about
progress note brevity or missing progress notes, both providers and medical leadership
expressed their belief this was acceptable documentation. The lack of negative feedback
in the provider performance reviews regarding a need to improve documentation
confirmed this belief. Medical leadership also reported WSP had no guidelines for
appropriate documentation. Poor documentation increased risk of medical errors,
including missed diagnostic examinations, and created extra work for medical staff
caring for the patient. Just prior to our on-site inspection, CCHCS had developed a
provider documentation policy, in which WSP medical leadership would train their staff
to follow.
57 HCDOM 3.1.8, Reception Center, c.2.A-C.
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Recommendations
• Medical leadership should analyze the causes of poor provider
documentation, including updating the patient problem lists, and implement
remedial measures as appropriate.
• Medical leadership should emphasize the necessity and importance of
appropriate provider EHRS chart review at each patient appointment.
• Medical leadership should clarify for providers the tasks required for RC-
focused health care assessments, appropriate durations for follow-up, and
expectations of the yard providers at the initial appointment after completing
focused health care assessments.
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Reception Center
This indicator focuses on the management of medical needs and continuity of care for
patients arriving from outside the department’s system. The OIG review includes
evaluating the institution’s performance in 1) providing and documenting initial health
screenings, initial health assessments, continuity of medications, and completion of
required screening tests; 2) addressing and providing significant accommodations for
disabilities and health care appliance needs; and 3) identifying health care conditions
needing treatment and monitoring. Patients reviewed for reception center (RC) care are
those received from nondepartmental facilities, such as county jails.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (70.4%)
WSP had a mixed performance in this indicator. Case review found nurses performed
well in assessments, interventions, and documentation for patients arriving to the RC.
However, we found opportunities for improvement in providers’ assessments and
providers’ thorough review of patients’ prior medical records. In addition, WSP also
needed improvement in timely completing intake RC screening tests and provider’s
review of the test results. Taking all these aspects into consideration, the OIG rated the
case review component of this indicator adequate.
Compliance testing showed WSP’s overall performance improved for this indicator. WSP
showed good performance in timely completing initial health screening forms,
assessment and disposition sections of the screening process, and history and physical
examinations. However, the institution needs to improve in offering and completing
screening laboratory tests and Valley Fever skin tests as well as reviewing and
communicating laboratory results. Factoring in all the information, the OIG rated the
compliance testing component of this indicator inadequate.
Case Review and Compliance Testing Results
Our clinicians reviewed nine cases and identified 12 deficiencies, seven of which were
significant.58
Provider Access
RC provider access was mixed. Compliance testing revealed good provider access:
providers often saw new patients received from county jails within the required time
frame (MIT 12.003, 87.5%), and they frequently evaluated patients and performed history
and physical examinations (H&Ps) within seven days (MIT 12.004, 85.0%). However, case
review clinicians found poor provider access in several of the nine RC cases we reviewed.
In three of these cases, patients were not seen until two weeks after their arrival. All
58 Deficiencies occurred in cases 2, 7, and 20. Cases 2, 7, and 20 had significant deficiencies.
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three cases were for patients with complex medication conditions who should have been
seen urgently.59 In addition, case review found multiple provider performance
deficiencies in RC care in two of the nine cases: cases 7 and 20. The deficiencies included
providers’ poor review of records and lapses in addressing critical medical conditions.
These deficiencies were discussed further in the Access to Care and Provider
Performance indicators.
Compliance testing showed WSP needed improvement in offering and completing intake
screening tests (MIT 12.005, 60.0%). Case review also found WSP performed poorly in
completing initial screening tests and the provider’s review of results, with deficiencies
cited in cases 7 and 54. This was discussed further in the Diagnostics and Provider
Performance indicators.
Nursing Performance
Compliance testing found nurses performed excellently in thoroughly completing the
initial health screening forms (MIT 12.001, 95.0%), and nurses timely signed and
completed the assessment and disposition portion of the health screening form (MIT
12.002, 100%).
OIG clinicians reviewed nine cases and found two nursing deficiencies, one of which was
significant60 as described below:
• In case 20, the nurse evaluated the new RC patient who had arrived from the
county jail. The patient had multiple medical chronic care issues including
suspected bladder cancer, blood in the urine for two months, diabetes, end-
stage renal disease requiring dialysis, anemia, and high blood pressure. The
patient reported a recent episode of blood in the urine. However, the nurse
did not consult with the provider for a further plan of care for this high-risk
patient and his reports of continued blood in the urine.
Clinician On-Site Inspection
During the clinician on-site inspection, WSP RC staff informed us they processed
patients through the various steps in the intake procedure. The RNs and LVNs were well
organized and fully staffed to handle a large number of patients. WSP staff informed us
approximately 400 new RC patients arrived weekly.
Medical leadership reported difficulty in transferring the sickest patients to a higher
acuity care institution for appropriate care. Medical leadership informed us, even though
the placement committees reviewed the cases and assigned patients to other institutions,
some higher acuity care institutions have created secondary hurdles the RCs had to
overcome for a patient to be considered for transfer. Medical leadership stated, even after
the initial approvals occurred, higher acuity care institution still commonly denied
transfer for WSP patients. When this occurred, CCHCS headquarters and WSP medical
leadership need to intervene, which delayed proper placement for the patient. As a high-
volume RC, timely transferring patients to their ultimate destinations was critical.
59 Significant deficiencies in RC provider access occurred in cases 2, 7, and 20.
60 Deficiencies occurred in cases 2 and 20. Case 20 had a significant deficiency.
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Staff stated a new diagnostic area would help in processing RC patients more efficiently
with being able to offer provider, mental health, dental, and laboratory services. This may
reduce delays in appointments for the RC process. In addition, the new diagnostic area
would include five TTA beds. At the time of our inspection, construction was near
completion for the diagnostic area, pending an opening date of June 5, 2023.
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Compliance Testing Results
Table 16. Reception Center
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Table 17. Other Tests Related to Reception Center
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Recommendations
• Medical leadership should determine causative factors related to the
untimely provision of patients’ RC screening laboratory tests and provider
communication of test results to their patients as stated in CCHCS policy.
• Nursing leadership should analyze the challenges to nursing staff on
following CCHCS policies and procedures for coccidioidomycosis (Valley
Fever) skin test reading and implement remedial measures as appropriate.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing,
monitoring, and intervening for medically complex patients requiring close medical
supervision. Our inspectors also evaluated the timeliness and quality of provider and
nursing intake assessments and care plans. We assessed staff members’ performance in
responding promptly when patients’ conditions deteriorated and looked for good
communication when staff consulted with one another while providing continuity of
care. Our clinicians also interpreted relevant compliance results and incorporated them
into this indicator. At the time of our inspection, WSP’s specialized medical housing
consisted of a correctional treatment center (CTC).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Proficient (85.0%)
WSP had a mixed performance in this indicator with case review. We found providers
evaluated patients in the CTC timely but often performed poor EHRS patient chart
reviews, did not document accurate evaluations, and did not provide documentation
showing any supporting assessments for the plan of care. Nursing staff assessed patients
routinely; however, nurses showed room for improvement in completing thorough
nursing assessments, interventions, and documentation. Factoring in all the information,
the OIG rated the case review component of this indicator inadequate.
Compliance testing showed WSP staff performed excellently in completing initial
assessments, history, and physical examinations within the required time frame as well as
in maintaining a functional call light system. One area for improvement was poor
medication continuity for patients newly admitted to the CTC. Considering all the
information, the OIG rated the compliance testing component of this indicator proficient.
Case Review and Compliance Testing Results
The CTC is a 16-bed unit, with 10 beds designated for medical patients. We reviewed
three CTC cases that included 37 provider events and 16 nursing events. Due to the
frequency of nursing and provider contacts in the specialized medical housing, we
bundled up to two weeks of patient care into a single event. We identified 38 deficiencies,
11 of which were significant.61
Provider Performance
Providers delivered mixed specialized medical housing care. Compliance testing showed
providers completed all admission history and physical examinations without delay (MIT
13.002, 100%). Case review also found providers performed well in timely completing
61 CTC deficiencies occurred in cases 52–54. Significant deficiencies occurred in cases 52–54.
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admission history and physicals, and also timely completed patient follow-up
appointments. However, in our three CTC cases, we identified 23 provider performance
deficiencies, eight of which were significant.62 Provider documentation was poor, EHRS
patient chart reviews were incomplete, and important medical conditions were not
always addressed. Examples of significant deficiencies are below:
• In case 52, the patient returned from the hospital with extensive facial
fractures and a brain bleed. The provider started a blood thinning medication
for this patient, which increased the risk of the existing brain bleed.
Although the scanned hospital records had recommendations to start the
blood thinning medication, the hospital’s records were incomplete at the
time the provider endorsed them. Specifically, the scanned hospital records
did not contain the neurosurgery and cardiac consultation reports to explain
why the blood thinner was needed. In addition, the provider’s supervisor, the
CME, advised the provider not to start the blood thinner.
• In case 54, the provider evaluated a new patient for a CTC admission. The
patient arrived with a low blood count and reduced kidney function. The
provider did not thoroughly evaluate the patient for possible causes of the
low blood count and reduced kidney function.
• Again, in case 54, the provider endorsed laboratory results indicating the
patient’s kidney function and low blood counts had worsened. The provider
did not address the patient’s worsening renal function and low blood counts,
or order an additional diagnostic examination to determine the cause. In
addition, the provider’s progress notes did not document the latest abnormal
laboratory results for almost five weeks after the results were available.
We also discuss the deficiencies in the Provider Performance indicator.
Nursing Performance
In both case review and compliance testing, patients admitted to the CTC received timely
initial health assessments (MIT 13.001, 100%). Compliance testing showed the CTC
maintained an operational call system to ensure patients had access to care (MIT 13.101,
100%). The case review clinicians found patients were assessed by nursing staff every
shift, but the assessments were often incomplete. Of the 37 deficiencies we identified in
the specialized medical housing cases, 10 deficiencies directly related to the quality of
nursing care, none of which was significant.63 Deficiencies mainly involved incomplete
assessments. Examples are described below:
• In case 52, the patient was admitted to the CTC with facial fractures and a
brain bleed. The admitting CTC nurse did not perform a detailed baseline
assessment to include an assessment of the eyes, the surrounding facial area,
and documentation of any missing teeth. However, three hours later, another
nurse documented the patient had swelling to the right eye. Later in the
62 Provider performance deficiencies occurred in cases 52–54. Significant deficiencies occurred in cases 52 and
54.
63 CTC nursing performance deficiencies occurred five times in case 54, four times in case 52, and once in case
53. None was significant.
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review period, the patient reported increasing blurred vision in the right eye.
The nurse did not perform a thorough eye examination to include a visual
acuity test and assessment of pupils. In addition, the nurse did not notify the
provider of the patient’s symptoms.
• In case 54, the diabetic patient on insulin, with multiple complex conditions,
including decreased kidney function, bilateral knee amputations, and a
swallowing disorder, was admitted to the CTC after a hospitalization. The
CTC nurse did not initiate care plans for the risk of aspiration or the risk for
impaired skin integrity due to bowel and bladder incontinence. In another
encounter, the patient complained of loose stools. For five days, the CTC
nurses did not complete thorough GI assessments. In addition, during
November 2022, CTC nurses intermittently documented the patient’s blood-
sugar checks on the medication administration record (MAR) without any
orders to check the blood sugar level.
Medication Administration
Compliance testing revealed patients who were admitted to the CTC only occasionally
received their medications timely (MIT 13.003, 40.0%).
Our clinicians identified five deficiencies related to medication management, three of
which were considered significant.64 We discuss this further in the Medication
Management indicator.
Clinician On-Site Inspection
The CTC had 10 medical beds, six mental health beds, and two negative pressure rooms
for respiratory isolation. At the time of our inspection, nine patients occupied the 10
medical beds, and six patients occupied the mental health beds.
The CTC was staffed 24 hours a day with RNs, LVNs, and psychiatric technicians (PT).
Staffing included three RNs for the morning and evening shifts, and two RNs on the
night shift. In addition, on the morning and evening shifts, an LVN and a PT were also
assigned to the unit. WSP had one designated CTC provider, who made rounds with
nursing staff and conducted daily morning huddles.
The case review clinicians attended the CTC daily huddle. The provider, the UM nurse,
the SRN, nurses, and mental health staff all participated in the huddle, which was well
organized.
64 Medication deficiencies occurred in cases 52-54. Significant deficiencies occurred in cases 53 and 54.
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Compliance Testing Results
Table 18. Specialized Medical Housing
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Recommendations
• Nursing leadership should analyze the causes of CTC nurses not completing
daily assessments thoroughly and implement remedial measures as
appropriate.
• Medical leadership should analyze the causes of CTC providers not
completing appropriate documentation, EHRS chart reviews, and not
addressing important medical issues.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. The OIG
clinicians focused on the institution’s performance in providing needed specialty care.
Our clinicians also examined specialty appointment scheduling, providers’ specialty
referrals, and medical staff’s retrieval, review, and implementation of any specialty
recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Inadequate Adequate (81.7%)
WSP performed poorly in specialty services with case review. Medical leadership
approved requests for referral promptly, and follow-up provider appointments after
specialty consultations occurred as ordered. On-site hemodialysis access for patients was
good. However, we found cases in which critical specialty services were not ordered due
to a lack of specialty availability. In addition, we identified provider delays in specialty
orders, and providers did not order specialty follow-up appointments until after the
specialty appointment was already scheduled. Providers did not review and endorse the
on-site specialist’s progress notes, which led to delayed medical care. We also found
several instances of missing, but clinically significant, specialty services documentation.
Overall, due to the severity of the findings, the OIG rated the case review component of
this indicator inadequate.
Compliance testing showed WSP performed sufficiently in this indicator. WSP provided
excellent access for medium- and routine-priority specialty services. The institution also
performed well in providing access for high-priority specialty services, and subsequent
follow-up appointments for high-, medium-, and routine-priority specialty services.
However, WSP scored low in timely scheduling preapproved specialty services. Factoring
in all the information, the OIG rated the compliance testing component of this indicator
adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 124 events related to specialty services, including 97 specialty
encounters, 20 nursing encounters, and seven provider encounters. Of the 97 specialty
encounters, nine were telemedicine specialty appointments, 20 were off-site procedures,
15 were off-site specialty consultations, and 49 were on-site specialty appointments. On-
site specialty appointments included hemodialysis procedures, hemodialysis nephrologist
monthly follow-ups, and referrals to the podiatrist, physical therapist, and registered
dietician.65 Due to the frequency of on-site hemodialysis procedures, we bundled these
procedures into monthly events. Thus, one “hemodialysis event” may include up to 10
65 Hemodialysis is procedure using a machine to filter blood when the kidneys are not functioning normally. A
nephrologist is a specialist who treats kidney conditions and diseases.
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“hemodialysis procedures.” We found 33 deficiencies in this category, 15 of which were
significant.66
Access to Specialty Services
WSP’s performance was mixed. Compliance testing found WSP performed excellently in
completing most high-priority, medium-priority, and routine-priority specialty
appointments within required time frames (MIT 14.001, 86.7%; MIT 14.004, 100%; MIT
14.007, 100%). Follow-up specialty appointments for high- and medium-priority referrals
occurred in a satisfactory percentage of cases (MIT 14.003, 80.0%, and MIT 14.006, 87.5%);
however, routine-priority specialty referral follow-up appointments only occurred 75.0
percent of the time (MIT 14.009).
Case review determined WSP performed poorly in obtaining off-site specialty access. We
found eight off-site specialty access deficiencies, five of which were significant.67
Examples of significant deficiencies include those described in the following cases:
• In case 20, the patient was transferred to WSP from a county jail, where he
had been initially diagnosed with bladder cancer, had been evaluated by
hematology and urology specialists, and was documented as likely having
metastatic disease. He had a pending a cystoscopy when transferred to
WSP.68 The patient was not seen by a bladder cancer specialist for 80 days
after arriving at WSP.
• Furthermore, in case 20, staff scheduled the initial urology appointment with
a telemedicine urologist, who could not perform the critically necessary on-
site cystoscopy and biopsy.69 Over five months after arriving at the
institution, the patient had still not received the required cystoscopy and
biopsy. The patient became severely anemic and required transfer to the
hospital. Fortunately, the hospital staff provided the patient the critically
needed cystoscopy and biopsy.
• In case 52, the patient saw a neurosurgeon to follow up on brain bleeding
after a head trauma. The neurosurgeon recommended the patient have an
arterial embolization to block the potentially bleeding artery.70 The
procedure was not done. The on-site provider documented she did not order
the procedure because WSP was unable to locate a service provider
contracted with the department or CCHCS who could perform the
procedure. WSP should have obtained the necessary services for this patient.
• In addition, in case 52, the patient sustained a bilateral lower jaw and a facial
fracture. The hospital discharge instructions documented the hospital had
scheduled the patient for surgery with the ENT specialist to ensure
66 Deficiencies occurred in cases 9, 12, 14–17, 19–21, 52, and 53. Significant deficiencies occurred in cases 12, 16,
20, 21, 52, and 53.
67 Deficiencies occurred in cases 17, 20, 21, 52, and 53. Significant deficiencies occurred in cases 20, 21 and 52.
68 A cystoscopy is a procedure using a tube with a camera to examine the bladder and urinary tract.
69 A biopsy is a medical procedure involving the extraction of sample cells or tissues for testing. It can help to
diagnose conditions such as cancer.
70 Arterial embolization is a procedure used to close a specific blood vessel.
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appropriate healing and jaw alignment. However, WSP staff were unable to
obtain a timely ENT appointment. Therefore, the patient’s surgery did not
occur, and the patient was not seen by an ENT specialist until almost one
month after the initial injury.
Provider Performance
Case review found, once referrals were ordered, medical leadership approved them
timely. In addition, compliance found provider postspecialty follow-up appointments
almost always occurred timely (MIT 1.008, 92.7%).
OIG clinicians identified 12 deficiencies related to provider specialty ordering, following
specialty recommendations, or ordering follow-up. Seven were considered significant.71
Examples include those in the following cases:
• In case 21, the provider evaluated the patient for a high-priority urology
follow-up appointment for left hydronephrosis in the patient’s only kidney.72
The provider documented he would order the specialty kidney scan that the
urologist recommended; however, the provider did not enter the order until
20 days later.
• In case 20, the urologist recommended a whole-body positron emission
tomography (PET) scan for a patient with a possible metastatic bladder
cancer.73 The patient had been incarcerated at WSP for over one month
without treatment or specialty services. The provider ordered the scan as a
medium-priority appointment instead of a high-priority one, which resulted
in the delay of care.
Case review identified a best practice by the PT, who sent patient progress reports and
requests for provider orders directly to providers via the message center, ensuring timely
patient follow-up.
Nursing Performance
Nursing performed adequately in assessing patients who returned to the facility from off-
site specialty appointments. Clinicians reviewed 20 nursing encounters and identified
two deficiencies, one of which was significant.74 This was discussed further in the
Nursing Performance indicator.
Health Information Management
Compliance testing showed WSP providers performed excellently in retrieving and
endorsing specialty reports (MIT 4.002, 90.0% and MIT 14.002, 100%), but needed
71 Deficiencies occurred in cases 9, 14, 19, 20, 21, 53, and 54. Significant deficiencies occurred in cases 20, 21,
and 54.
72 Hydronephrosis is a condition of excess urine accumulating in the kidneys that causes swelling of the
kidneys.
73 A positron emission tomography (PET) scan is an imaging test of organs and soft tissues.
74 Nursing performance deficiencies occurred in cases 20 and 53. A significant deficiency occurred in case 20.
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improvement in provider endorsement of medium-priority and routine-priority specialty
reports (MIT 14.005, 60.0% and MIT 14.008. 66.7%).
Our case review clinicians identified seventeen deficiencies related to HIM, eight of
which were significant.75 Examples of significant deficiencies include those in the
following cases:
• In case 16, the on-site nephrologist evaluated the patient for hemodialysis,
end-stage renal disease, and acute anemia. The nephrologist followed up on a
recent laboratory test indicating the patient had worsening anemia. The
nephrologist documented the anemia could have been due to hemolysis or
laboratory error, ordered a repeat blood test, and recommended the patient
be referred to a hematologist (blood specialist) if the patient was still anemic.
Five days later, the patient’s blood count test result remained low; however,
the on-site WSP providers did not endorse either the on-site nephrologist’s
consultation progress notes or the nephrologist’s laboratory test results.
Thus, providers did not address the abnormal test results and missed the
nephrologist’s order regarding the hematology specialty referral.
• In case 52, the ENT specialist saw the patient for a follow-up appointment
regarding a mandibular fracture. HIM did not scan the ENT consultation
report until after our on-site questioning identified the missing
documentation. As a result, HIM staff scanned the correct document nearly
eight months after the ENT consultation occurred.
• In case 53, the patient was scheduled to see a hematology specialist. The
November hematology specialty consultation report was missing from the
EHRS. After our on-site questions identified this missing report, the OIG
found the report was subsequently scanned into the EHRS. Again, as a result,
the provider endorsed and scanned this report nearly six months after the
specialty appointment.
OIG clinicians found providers did not endorse on-site specialty consultation progress
notes, including nephrology, podiatry, and physical therapy progress notes. Unendorsed
on-site specialty progress notes were problematic in that providers were not only
unaware of the specialist’s status reports on the patient, but providers could not then
follow any specialty recommendations included in those reports. Examples include the
following cases:
• In case 20, the on-site kidney specialist documented the patient required
referral to a urinary system specialist for suspected bladder cancer. The
specialist’s progress note was not endorsed; consequently, the WSP provider
did not write an order for the specialty referral for 25 more days, 40 days after
the patient’s arrival to WSP.
75 Specialty health information management deficiencies occurred in cases 9, 12, 15, 16, 20, 52, and 53.
Significant deficiencies occurred in cases 12, 20, 52, and 53.
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• Also in case 20, the kidney specialist evaluated the patient and documented
Epogen must be discontinued due to the patient’s possible bladder cancer.76
The specialist’s report was not endorsed by a provider; thus, WSP providers
did not discontinue the medication until over one month later. However, this
error was mitigated because, although the order for Epogen remained active,
the hemodialysis unit did not administer Epogen during this time.
Clinician On-Site Inspection
We discussed specialty services with WSP medical leadership, UM nurses, HIM, specialty
supervisors and staff, nurses, and providers. As an RC, providers and medical leadership
stated most specialty referrals were delayed until patients arrived at their home
institutions, except for critically needed services such as emergency care and
hemodialysis. Since WSP is an RC with limited capacity, transferring patients to their
home institutions as expediently as possible was necessary. Ordering nonurgent referral
could have required a medical hold and delayed the patient’s transfer. If a patient was
transferred with a medical referral already ordered and the home institution was located
outside the WSP service region, the referral would need to be canceled and reissued at
the home institution. Medical leadership reported patients may refuse services because,
at RCs, they could not accumulate points toward early release, receive visitors or
packages, and were denied other “perks” until they were sent to the home institution.
We learned medical leadership did not require primary care providers to review or
endorse on-site specialty progress notes, which could delay patient care. In addition,
medical leadership did not expect primary care providers to review or endorse
nephrology-ordered laboratory work, which may also delay patient care.
WSP had an on-site HDU with six bays, run by a contracted vendor. This on-site specialty
unit increased availability to the dialysis patients and may have mitigated patient
transport costs. Medical leadership reported this HDU supported both WSP and North
Kern Valley State Prison. The HDU nurses managed the daily unit operation through
documented nurse protocols to handle many significant medical conditions such as
anemia, abnormal potassium levels, and fluid overload or deficit. The HDU nurses
contacted the kidney specialist if there were abnormal laboratory test results or changes
in the patient’s condition. A kidney specialist evaluated each dialysis patient once a
month.
The CCHCS headquarters renal transplant team evaluated end-stage renal disease and
dialysis patient for kidney transplant. Once a kidney was identified for a patient, at least
two months of medical records must be available and sent along with the patient to the
renal transplant specialist within very short time frames. Having the laboratory work and
direct entry of HDU specialty paperwork immediately accessible expedited this process.
Medical leadership reported challenges with poor communication from sending county
jails regarding patient health requirements. The CME stated WSP had received new
dialysis patients from county jails who had elevated blood pressures and swelling due to
increased fluid in the body, requiring immediate dialysis; however, the sending county
jail often did not notify WSP the patient was arriving or what medical treatment would be
76 Epogen is a medication used to treat anemia, a condition with low red blood cell count. Epogen can accelerate
tumor growth and may increase risks for cancer patients.
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needed on arrival. By not communicating this information to WSP, patients may be at a
higher medical risk and could have required emergency hospital evaluations if WSP staff
were unable to coordinate care within their institution.
Specialty services staff stated, due to cross-training staff, they did not experience staff
shortages; however, they had shortages in some specialty services. During the review
period, optometry services had a large backlog of 200 to 300 patients, due to the absence
of the optometrist. However, we did not identify deficiencies with this specialty in our
case reviews. In addition, the physical therapist no longer provided service to WSP. Staff
reported optometry and physical therapy were the most difficult specialty services to
obtain.
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Compliance Testing Results
Table 19. Specialty Services
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Table 20. Other Tests Related to Specialty Services
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Recommendations
• CCHCS and WSP medical leadership should consider developing and
implementing strategies to improve communication with county jails to
ensure WSP can be prepared for the medical needs of high-risk patients on
their arrival.
• Medical leadership should determine causative factors related to the
untimely provision or scheduling of patients’ specialty service
appointments and implement remedial measures as appropriate.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care administrative
processes. Our inspectors examined the timeliness of the medical grievance process and
checked whether the institution followed reporting requirements for adverse or sentinel
events and patient deaths. Inspectors checked whether the Emergency Medical Response
Review Committee (EMRRC) met and reviewed incident packages. We investigated and
determined whether the institution conducted required emergency response drills.
Inspectors also assessed whether the Quality Management Committee (QMC) met
regularly and addressed program performance adequately. In addition, our inspectors
determined whether the institution provided training and job performance reviews for its
employees. We checked whether staff possessed current, valid professional licenses,
certifications, and credentials. The OIG rated this indicator solely based on the
compliance score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (74.9%)
WSP’s performance was mixed in this indicator. While the institution scored well in
some applicable tests, it showed room for improvement in several areas. During our
review period, the EMRRC did not complete any required checklists. In addition, the
institution conducted a medical emergency response drill, but with incomplete
documentation. The institution did not consistently report patient deaths in a timely
manner to CCHCS. Lastly, nurse educators intermittently ensured nurses who
administered medication had completed their annual competency testing in a timely
manner and did not ensure newly hired nurses received the required onboarding training.
These findings are set forth in the table below. The OIG rated this indicator inadequate.
Compliance Testing Results
Nonscored Results
At WSP, the OIG did not have any applicable adverse sentinel events requiring root cause
analysis during our inspection period (MIT 15.001, N/A).
Our testing period reviewed mortality reports completed both before and after the
effective revision date of the CCHCS mortality review policy requirements. Prior to May
2022, we obtained CCHCS Death Review Committee (DRC) reporting data. Three
unexpected (Level 1) deaths occurred during our review period. In our inspection, we
found the DRC did not complete any death review reports promptly. The DRC finished
one report 55 days late and submitted it to the institution’s CEO 48 days late. The
remaining two death reports were overdue at the time of the OIG’s inspection. Effective
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May 2022, we obtained CCHCS Mortality Case Review reporting data. At the time of our
inspection, for two patients, we found no evidence in the submitted documentation of the
Preliminary Mortality Report having been completed. These reports were overdue at the
time of the OIG’s inspection (MIT 15.998).
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Compliance Testing Results
Table 21. Administrative Operations
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Recommendations
The OIG offers no recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to review
CCHCS policies and procedures, relevant court orders, and guidance developed by the
American Correctional Association. We also reviewed professional literature on
correctional medical care; reviewed standardized performance measures used by the
health care industry; consulted with clinical experts; and met with stakeholders from the
court, the receiver’s office, the department, the Office of the Attorney General, and the
Prison Law Office to discuss the nature and scope of our inspection program. With input
from these stakeholders, the OIG developed a medical inspection program that evaluates
the delivery of medical care by combining clinical case reviews of patient files, objective
tests of compliance with policies and procedures, and an analysis of outcomes for certain
population-based metrics.
We rate each of the quality indicators applicable to the institution under inspection based
on case reviews conducted by our clinicians or compliance tests conducted by our
registered nurses. Figure A–1 below depicts the intersection of case review and
compliance.
Figure A–1. Inspection Indicator Review Distribution for WSP
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of
its stakeholders, which continues in the Cycle 7 medical inspections. Below, Table A–1
provides important definitions that describe this process.
Table A–1. Case Review Definitions
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The OIG eliminates case review selection bias by sampling using a rigid methodology.
No case reviewer selects the samples he or she reviews. Because the case reviewers are
excluded from sample selection, there is no possibility of selection bias. Instead,
nonclinical analysts use a standardized sampling methodology to select most of the case
review samples. A randomizer is used when applicable.
For most basic institutions, the OIG samples 20 comprehensive physician review cases.
For institutions with larger high-risk populations, 25 cases are sampled. For the
California Health Care Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected institution and
from CCHCS. Our analysts then apply filters to identify clinically complex patients with
the highest need for medical services. These filters include patients classified by CCHCS
with high medical risk, patients requiring hospitalization or emergency medical services,
patients arriving from a county jail, patients transferring to and from other departmental
institutions, patients with uncontrolled diabetes or uncontrolled anticoagulation levels,
patients requiring specialty services or who died or experienced a sentinel event
(unexpected occurrences resulting in high risk of, or actual, death or serious injury),
patients requiring specialized medical housing placement, patients requesting medical
care through the sick call process, and patients requiring prenatal or postpartum care.
After applying filters, analysts follow a predetermined protocol and select samples for
clinicians to review. Our physician and nurse reviewers test the samples by performing
comprehensive or focused case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the clinicians review
medical records, they record pertinent interactions between the patient and the health
care system. We refer to these interactions as case review events. Our clinicians also
record medical errors, which we refer to as case review deficiencies.
Deficiencies can be minor or significant, depending on the severity of the deficiency. If a
deficiency caused serious patient harm, we classify the error as an adverse event. On the
next page, Figure A–2 depicts the possibilities that can lead to these different events.
After the clinician inspectors review all the cases, they analyze the deficiencies, then
summarize their findings in one or more of the health care indicators in this report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and compliance
inspectors. Analysts follow a detailed selection methodology. For most compliance
questions, we use sample sizes of approximately 25 to 30. Figure A–3 below depicts the
relationships and activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT) questions to
determine the institution’s compliance with CCHCS policies and procedures. Our nurse
inspectors assign a Yes or a No answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain information,
allowing them to answer most of the MIT questions. Our regional nurses inspect each
institution. They interview health care staff, observe medical processes, test the facilities
and clinics, review employee records, logs, medical grievances, death reports, and other
documents, and obtain information regarding plant infrastructure and local operating
procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for each of the
questions applicable to a particular indicator, then averages the scores. The OIG
continues to rate these indicators based on the average compliance score using the
following descriptors: proficient (85.0 percent or greater), adequate (between 84.9 percent
and 75.0 percent), or inadequate (less than 75.0 percent).
Indicator Ratings and the Overall Medical
Quality Rating
The OIG medical inspection unit individually examines all the case review and
compliance inspection findings under each specific methodology. We analyze the case
review and compliance testing results for each indicator and determine separate overall
indicator ratings. After considering all the findings of each of the relevant indicators, our
medical inspectors individually determine the institution’s overall case review and
compliance ratings.
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Appendix B. Case Review Data
Table B–1. WSP Case Review Sample Sets
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Table B–2. WSP Case Review Chronic Care Diagnoses
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Table B–3. WSP Case Review Events by Program
Table B–4. WSP Case Review Sample Summary
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Appendix C: Compliance Sampling Methodology
Wasco State Prison
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California Correctional Health Care Services’
Response
March 25, 2024
Amarik Singh, Inspector General
Office of the Inspector General
10111 Old Placerville Road, Suite 110
Sacramento, CA 95827
Dear Ms. Singh:
California Correctional Health Care Services (CCHCS) has reviewed the draft Medical Inspection
Report for WascoState Prison(WSP)conducted by the Office of the Inspector General (OIG) from
July 2022 to December 2022.During this timeframe, 8,392 primary care provider (PCP)
encounters, not including Triage and Treatment Area visits, were completed.In contrast, the OIG
inspection reviewed approximately 1%or 120PCP encounters,which arenot indicative of the
quality of care delivered to the patient population at WSP.
If you have any questions or concerns, please contact me at (916) 691-3747.
Sincerely,
DeAnna Gouldy
Deputy Director
Policy and Risk Management Services
California Correctional Health Care Services
cc: Diana Toche, D.D.S., Undersecretary, Health Care Services, CDCR
Clark Kelso, Receiver
Directors, CCHCS
Roscoe Barrow, Chief Counsel, CCHCS Office of Legal Affairs
Renee Kanan, M.D., Deputy Director, Medical Services, CCHCS
Barbara Barney-Knox, R.N., Deputy Director, Nursing Services, CCHCS
Annette Lambert, Deputy Director, Quality Management, CCHCS
Robin Hart, Associate Director, Risk Management Branch, CCHCS
Regional Executives, Region III, CCHCS
Chief Executive Officer, WSP
Heather Pool, Chief Assistant Inspector General, OIG
Doreen Pagaran, R.N., Nurse Consultant Program Review, OIG
Amanda Elhardt, Report Coordinator, OIG
P.O. Box 588500
Elk Grove, CA 95758
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June 19, 2024, OIG Response to March 25, 2024, Letter
Regarding WSP Report
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Office of the Inspector General, State of California Inspection Period: July 2022 – December 2022 Report Issued: June 2024
Cycle 7
Medical Inspection Report
for
Wasco State Prison
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Neil Robertson
Chief Deputy Inspector General
STATE of CALIFORNIA
June 2024
OIG