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Home My WebLink About1718-7 SO-Jail Inmate Health Services (Standards) report (7-19-18 Final)Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Sheriff’s Office – Jail Inmate Health Services (Standards work) To request this information in an alternate format, please call (541) 330-4674 or send email to David.Givans@Deschutes.org Deschutes County, Oregon David Givans, CPA, CIA, CGMA County Internal Auditor 1300 NW Wall St Bend, OR 97703 Audit committee: Daryl Parrish, Chair - Public member John Barnett - Public member Tom Linhares - Public member Lindsey Lombard - Public member Jared Standerwick - Public member Wayne Yeatman - Public member Anthony DeBone, County Commissioner Nancy Blankenship, County Clerk Dan Despotopulos, Fair & Expo Director Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 TABLE OF CONTENTS: HIGHLIGHTS 1. INTRODUCTION 1.1. Background on Audit …………..……………………………………………………………. 1 1.2. Objectives and Scope ……………….……………………………….…………………… 1-2 1.3. Methodology …………………………………….…………………………………………….… 2 1.4. Background on standards for jail inmate health care ………………….… 3-4 2. OBSERVATIONS 2.1. Observations on NCCHC Standards Compliance .........………………...… 5-8 3. MANAGEMENT RESPONSE Deschutes County Sheriff’s Office …………………………………………………....……. 9 4. APPENDIX NCCHC (2014)-Compliance detail by standard as of 6/2018 ……..… 10-13 Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 HIGHLIGHTS Why this audit was performed: To identify gaps to seeking compliance with standards for health services in jails under the NCCHC (2014). What was recommended: Recommendation was to assess whether and to what extent they want to implement some additional health standards to help them improve the services provided to inmates. Sheriff’s Office - Jail Inmate Health Services (Standards Work) This audit report is the completion of the standards work started in 17/18-3. Please review that report for additional context. This audit report covers the third objective which was to with the assistance of appropriate levels of jail staff, identify estimated gaps to seeking compliance with standards for health services in jails (NCCHC – National Commission on Correctional Health Care). These NCCHC standards (2014 version) were promulgated to improve the correctional health services and help correctional facilities provide effective and efficient care. Using these standards is meant to reduce risk of adverse patient outcomes and legal judgments. These standards are intended to be used by jails of all sizes. NCCHC offers accreditation programs. The Oregon Department of Corrections, Multnomah County, Washington County, and Linn County are currently accredited. What was found This was an initial effort by the Sheriff’s Office to electively assess compliance to these standards. Overall, 79% of the standards were at a level of compliant or partially compliant. Adoption of additional standards would be voluntary and the Sheriff’s Office has not yet determined what standards and to what extent they may adopt them. Deschutes County Internal Audit Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 1 1. Introduction 1.1 BACKGROUND ON AUDIT Audit Authority: The Deschutes County Audit Committee authorized the audit of jail inmate health services in the 2017-2019 Internal Audit Program Work Plan. The Sheriff’s Office participated in the development of the audit objectives. 1.2 OBJECTIVES AND SCOPE “Audit objectives” define the goals of the audit. Objectives: The objectives were: 1) {See Report 17/18-3} Gather information on how jail inmate health costs and services are trending and the nature of the inmate needs. 2) {See Report 17/18-3} Utilize inmate health care service activity levels and costs to consider potential recommendations for meeting care standards / staffing levels. 3) With assistance of appropriate levels of jail staff, identify estimated gaps to seeking compliance with standards for health services in jails (NCCHC – National Commission on Correctional Health Care ) 4) Be aware of any issues with compliance with federal and state regulations and requirements (HIPAA/42 CFR), as may be applicable. Scope and timing (standards): This segment of audit work occurred in June 2018. The NCCHC standards (2014) were selected in discussions with Jail management and evaluated with the assistance of Jail medical staff. The sufficiency of this effort is purely to evidence where there may be gaps in meeting these NCCHC standards. The Deschutes County Jail has not decided at this point to follow these standards. The Deschutes County jail is accredited under the Oregon Jail standards. These standards encompass Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 2 all jail operations, including medical. The NCCHC standards are specifically medical and are more detailed. Note: As of the issuance of the report, the NCCHC issued their 2018 revision of the standards. It is understood, with these revisions, many of these standards were modified and the assessment of compliance with this audit may change under these new standards. It is understood that some of the gaps in compliance may be less under the new standards. 1.3 METHODOLOGY “Audit procedures are created to address the audit objectives” Audit procedures included:  Interviewed staff and reviewed practices and procedures.  Reviewed research and reports on correction/jail inmate health matters.  Reviewed Oregon statutory requirements for inmate medial (ORS 169), as well as Oregon Jail Standards and NCCHC standards.  Coordinated and reviewed NCCHC standards compliance by jail medical staff. o (Nurse Lyndsey Doran and Lt. Michael Gill)  Developed and analyzed NCCHC standards responses. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. (2011 Revision of Government Auditing Standards, issued by the Comptroller General of the United States.) Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 3 1.4 BACKGROUND ON STANDARDS FOR JAIL INMATE HEALTH CARE Oregon medical standards for jails are outlined in ORS 160.076. These jail standards lay out the statutory minimum requirements that jails must adhere to. Oregon Jail Standards refer to voluntary standards promulgated by the Oregon State Sheriff’s Association (OSSA), and followed by every jail in Oregon. These have been codified into the Sheriff’s Office policies and procedures. The Sheriff’s Office is accredited under these standards. There are also a number of standard setting bodies providing some jail medical standards including: • National Commission on Correctional Health Care (NCCHC), • Oregon Accreditation Alliance, • American Jail Association (AJA), • American Correctional Association (ACA), • National Institute of Corrections (NIC), and • Commission on Accreditation on Correction (CAC). The Sheriff’s Office thinks the NCCHC standards contain the best jail medical standards and wanted to see how the jail’s practices compared to those standards. During the time of the audit, the Sheriff’s Office consulted with a past Director of Corrections Health for Multnomah County, Oregon where they had followed NCCHC standards and were familiar with the process for becoming accredited under those standards. NCCHC Standards (2014) These standards were promulgated to improve the correctional health services and help correctional facilities provide effective and efficient care. Using these standards is meant to reduce risk of adverse patient outcomes and legal judgments. These standards are intended to be used by jails of all sizes. Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 4 The sixty-seven (67) standards are grouped under nine areas: • Governance and Administration • Safety • Personnel and Training • Health Care Services and Support • Patient Care and Treatment • Health Promotion • Special Needs and Services • Health records • Medical Legal Issues Each standard is also classified as either “essential” or “important,” which is used for accreditations purposes. Accreditation under the NCCHC Standards requires compliance with 100% of the applicable “essential” standards and at least 85% of the applicable “important” standards. NCCHC offers accreditation programs. The Oregon Department of Corrections, Multnomah County, Washington County, and Linn County are currently accredited. Their accreditation programs available include health, mental health, and opioid treatment programs. They have nearly 500 facilities accredited around the country. Note: This work towards investigating application and identification of better medical standards indicates the drive of the Sheriff’s Office to continue to strengthen their health services provided to inmates. 2. Observations The audit included procedures to understand the gaps to compliance with NCCHC standards. Audit findings result from incidents of non-compliance with stated procedures and/or departures from prudent operation. The audit was neither designed nor intended to be a detailed study of every relevant system, procedure, or transaction. Accordingly, the opportunities for improvement presented in the report may not be all-inclusive of areas where improvement may be needed and does not replace efforts needed to design an effective system of internal control. Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 5 The findings noted in this report were not considered significant deficiencies. A significant deficiency is defined as an internal control deficiency that could adversely affect the entity’s ability to initiate, record, process, and report financial data consistent with the assertions of management in the financial statements. 2.1 OBSERVATIONS ON NCCHC STANDARDS COMPLIANCE GRAPH I Overall compliance evaluation Summary of compliance to the NCCHC standards (2014). This was an initial effort by the Sheriff’s Office to electively assess to these standards a level of compliance. Overall, 79% of the standards were at a level of compliant or partially compliant. In discussions with the Sheriff’s Office, it was clear that they wanted to further explore the non- compliant and partial compliant areas to see how these could be brought into compliance. Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 6 TABLE I Overall compliance by class (essential/ important) TABLE II Compliance by section and class (essential/ important) Compliant Partially Compliant Non Compliant Totals Count % of section Count % of section Count % of section Count % of section ESSENTIAL 18 45% 15 38% 7 18% 40 100% IMPORTANT 11 41% 9 33% 7 26% 27 100% TOTAL 29 43% 24 36% 14 21% 67 100% For accreditation, 100% of the “essential” standards must be met and 85% of the “important” standards. NCCHC Section CLASS Compliant Partially Compliant Non Compliant Totals Governance and Administration 18% 55% 27% 100% Essential 25% 50% 25% 100% Important 0% 67% 33% 100% Health Care Services and Support 60% 40% 0% 100% Essential 67% 33% 0% 100% Important 50% 50% 0% 100% Health Promotion 33% 33% 33% 100% Important 33% 33% 33% 100% Health records 100% 0% 0% 100% Essential 100% 0% 0% 100% Important 100% 0% 0% 100% Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 7 TABLE II, continued NCCHC Section CLASS Compliant Partially Compliant Non Compliant Totals Medical Legal Issues 33% 17% 50% 100% Essential 0% 50% 50% 100% Important 50% 0% 50% 100% Patient Care and Treatment 46% 31% 23% 100% Essential 50% 20% 30% 100% Important 33% 67% 0% 100% Personnel and Training 33% 33% 33% 100% Essential 40% 40% 20% 100% Important 25% 25% 50% 100% Safety 60% 40% 0% 100% Essential 50% 50% 0% 100% Important 67% 33% 0% 100% Special Needs and Services 45% 45% 9% 100% Essential 50% 50% 0% 100% Important 33% 33% 33% 100% TOTAL 43% 36% 21% 100% Additional details down to the standard are in the Appendix. Additional observations. The Sheriff’s Office through its accreditation process and policies and procedures appears to have already exceeded the minimum levels required by statute. Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 8 The NCCHC standards represent some best practices for jail health operations. As indicated earlier, the State’s Department of Corrections, as well as Multnomah, Washington, and Linn counties have adopted these standards. A recent PEW report 1 titled “Jails: Inadvertent Health Care Providers” highlighted the trend for county jails to contract out for health services. In the RFP’s reviewed, they indicated 82% of the RFP’s cite at least one standard from NCCHC or ACA. As indicated in the prior report (17/18-3), Deschutes County is among the few large Oregon counties that doesn’t outsource its health services. Also in this report, it was recommended for the Sheriff’s Office to consider its options for outsourcing. Regardless of the outcome of this review, utilizing health standards to guide and improve practices will strengthen the services provided. Correctional health standards appear to help provide effective and efficient care while reducing risk of adverse patient outcomes and legal judgments. Those not utilizing best practice standards will always find themselves on the defense if problems occur, even if statutory mandates are met. It is recommended for the Sheriff’s Office to assess whether and to what extent they want to implement some additional health standards to help them improve the services provided to inmates. 1 Jails: Inadvertent Health Care Providers–How County correctional facilities are playing a role in the safety net – The PEW Charitable Trust Jan 2018 Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 9 3. MANAGEMENT RESPONSE Deschutes County Sheriff’s Office To: David Givans, County Internal Auditor From: Captain Michael Shults Subject: Management’s response to Audit report It is recommended for the sheriff’s Office to assess whether and to what extent they want to implement some additional health standards to help them improve the services provided to inmates. The Deschutes County Sheriff’s Office Jail is required to by the Constitution and Oregon law to provide emergency medical and dental health care. Adequate health care screening, examination, diagnosis, and treatment must be provided to inmates. It is important to the Sheriff’s Office that our health care system ensure a reasonable effort to provide adequate health care services. The Sheriff’s Office is currently accredited in the Oregon Accreditation Alliance since 2002. We believe that becoming a Certified Correctional Health Facility can benefit our operations in many ways. Standards serve as a framework to ensure that systems, policies and procedures are in keeping with nationally recognized best practices. Compliance ensures that everyone on the team knows what is expected. We also know that the accreditation process provides an independent, professional assessment of standards that have been proven to be effective tool to improve the health of inmates, increase efficiencies in the health service delivery, and reduce risk. The Deschutes County Sheriff’s Office believes that we can move forward to implementing many of the recommended standards as outlined in their just published Standards for Health Services in Jails (2018). Over the next year we will be looking at the standards as we update current policies and procedures. We will use the published Standards to help improve our overall services delivery. We will also evaluate becoming accredited next fiscal year to determine if we have enough money in the budget to be part of the accreditation process. I appreciate the Audit Committee’s recommendation as we move forward. Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 10 4. APPENDIX – NCCHC(2014) compliance detail by standard as of 6/2018 NCCHC (2014) compliance detail by standard as of 6/2018 Compliant Partially compliant Non compliant NCCHC Section & number Description Essential Important Governance and Administration 8 3 J-A-01 Access to care J-A-02 Responsible Health Authority J-A-03 Medical Autonomy J-A-04 Administrative meetings and reports J-A-05 Policies & Procedures J-A-06 Continuous Quality Improvement Program J-A-07 Emergency response plan J-A-08 Communication on Patient's Health needs J-A-09 Privacy of care J-A-10 Procedure in the event of inmate death J-A-11 Grievance mechanism for Health Complaints Health Care Services and Support 3 2 J-D-01 Pharmaceutical operations J-D-02 Medications services J-D-03 Clinic space, equipment, and supplies J-D-04 Diagnostic services J-D-05 Hospital and Specialty care 2 1 -1 2 -1 2 1 1 -1 1 1 -1 1 1 Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 11 NCCHC (2014) compliance detail by standard as of 6/2018 Compliant Partially compliant Non compliant NCCHC Section & number Description Essential Important Health Promotion 3 J-F-01 Healthy Lifestyle promotion J-F-02 Medical Diets J-F-03 Use of Tobacco Health records 2 2 J-H-01 Health records format and contents J-H-02 Confidentiality of Health records J-H-03 Management of Health Records J-H-04 Access to custody information Medical Legal Issues 2 4 J-I-01 Restraint and seclusion J-I-02 Emergency Psychotropic Medication J-I-03 Forensic Information J-I-04 End-of-life Decision Making J-I-05 Informed consent and right to refuse J-I-06 Medical and other research Patient Care and Treatment 10 3 J-E-01 Information on Health Services J-E-02 Receiving screening J-E-03 Transfer screening J-E-04 Initial Health Assessment 2 1 -1 Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 12 NCCHC (2014) compliance detail by standard as of 6/2018 Compliant Partially compliant Non compliant NCCHC Section & number Description Essential Important J-E-05 Mental Health Screening and Evaluation J-E-06 Oral Care J-E-07 Non-emergency health care requests and services J-E-08 Emergency Services J-E-09 Segregated Inmates J-E-10 Patient Escort J-E-11 Nursing Assessment Protocols J-E-12 Continuity and coordination of care during incarceration J-E-13 Discharge planning Personnel and Training 5 4 J-C-01 Credentials J-C-02 Clinical performance enhancement J-C-03 Professional development J-C-04 Health trainings for correctional officers J-C-05 Medication Administration training J-C-06 Inmate workers J-C-07 Staffing J-C-08 Health care liaison J-C-09 Orientation for health staff Safety 2 3 J-B-01 Infection prevention and control program 2 1 -1 Sheriff’s Office - Jail Inmate Health Services report #1718-7 July 2018 March 2018 Page 13 NCCHC (2014) compliance detail by standard as of 6/2018 Compliant Partially compliant Non compliant NCCHC Section & number Description Essential Important J-B-02 Patient safety J-B-03 Staff Safety J-B-04 Federal sexual abuse regulations J-B-05 Response to sexual abuse Special Needs and Services 8 3 J-G-01 Chronic Disease Services J-G-02 Patients with Special Health Needs J-G-03 Infirmary Care J-G-04 Basic Mental Health Services J-G-05 Suicide Prevention Program J-G-06 Patients with Alcohol and other drug problems J-G-07 Intoxication and Withdrawal J-G-08 Contraception J-G-09 Counseling and care of the pregnant inmate J-G-10 Aids to impairment J-G-11 Care for terminally ill Grand Total 40 27 {End of Report} Please take a survey on this report by clicking on the attached link: https://www.surveymonkey.com/r/SO-Jail_Inmate_Health_Standards_1718-7 2 1 -1