Audit of the Hampshire County Sheriff’s Office—A Review of Healthcare and Inmate Deaths Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Hampshire County Sheriff’s Office—A Review of Healthcare and Inmate Deaths.

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of the Hampshire County Sheriff’s Office (HSO) for the period July 1, 2019 through June 30, 2021.

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.

Below is a list of our audit objectives, indicating each question we intended our audit to answer; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.

Objective	Conclusion
Did HSO comply with and implement the requirements of Section 932.17(2) of Title 103 of the Code of Massachusetts Regulations (CMR) and HSO’s Policy 4.4.15 (Notification of Death of Employee or Inmate) regarding the deaths of inmates in its custody?	Yes
Did HSO hold quarterly meetings with the health authority and review quarterly reports regarding healthcare services for inmates in accordance with 103 CMR 932.01(3)?	Yes
Did HSO provide its inmates with initial medical screenings upon admission and a health assessment within seven days after admission, in accordance with 103 CMR 932.06 and 932.07?	No; see Finding 1
Did inmates at HSO receive medical care after submission of a sick call request form in accordance with HSO’s Policy 4.3.2 (Medical Requests/Sick Call), and did HSO document the medical care its inmates received in accordance with 103 CMR 932.18(2)(h) and (k)?	Yes

 

To accomplish our objectives, we gained an understanding of HSO’s internal control environment related to the objectives by reviewing HSO’s internal control plan and applicable agency policies and procedures, as well as by interviewing HSO’s management. We evaluated the design and implementation of the internal controls related to our audit objectives. We also tested the operating effectiveness of the supervisory review controls on initial medical screenings (see Finding 1). To obtain sufficient, appropriate evidence to address our audit objectives, we conducted the following procedures.

Inmate Deaths

We inspected the list of inmate deaths that occurred during the audit period, which HSO management provided to us. This list included one inmate who died in HSO’s custody on November 1, 2020 and whose cause of death was reported as natural causes. To determine whether HSO complied with 103 CMR 932.17(2) and HSO’s Policy 4.4.15 regarding the deaths of inmates in its custody, we performed the following procedures:

• We inspected HSO’s Policy 4.4.15 to determine whether HSO had guidelines that include the following requirements listed in 103 CMR 932.17(2):

              (a)  internal notification to include medical and administrative staff;

              (b)  procedures when discovering body;

              (c)  disposition of the body;

             (d)  notification of next of kin;

             (e)  [Criminal Offender Record Information] notification [sent to victim(s) of an inmate] as soon as                           practicable [when such notification is necessary];

              (f)   investigation of causes;

             (g)  reporting and documentation procedures;

             (h)  procedure for review of incident by appropriate designated staff with a final report submitted to all                     appropriate parties.

• To determine whether HSO complied with and implemented the requirements of 103 CMR 932.17(2) and HSO’s Policy 4.4.15 regarding the one in-custody death that occurred during the audit period, we performed the following procedures:
  • We examined HSO’s main control log and the one “Man Down” Drill Evaluation Form related to this in-custody death to ensure that medical and administrative employees were notified about the inmate’s condition, resulting in the inmate’s transportation to the Cooley Dickinson Hospital by ambulance.
  • We examined the “Man Down” Drill Evaluation Form to ensure that correctional officers and in-house healthcare employees performed life-saving measures on the inmate, as appropriate. We also examined HSO’s main control log to ensure that the shift supervisor notified (1) HSO employees in the chain of command and (2) the inmate’s next of kin about the inmate’s death.
  • We interviewed HSO management about whether a Criminal Offender Record Information notification was needed.

We noted no exceptions in our testing; therefore, we determined that HSO complied with and implemented the requirements of 103 CMR 932.17(2) and HSO’s Policy 4.4.15 regarding in-custody deaths.

Quarterly Meetings

To determine whether HSO held quarterly meetings with the health authority and reviewed quarterly reports in accordance with 103 CMR 932.01(3), we examined the minutes of 100% (eight) of the quarterly meetings that took place during the audit period between HSO and its health authority. We also examined 100% (two) of the annual statistical summary reports that the health authority provided to HSO during the audit period.

We noted no exceptions in our testing; therefore, we determined that HSO held quarterly meetings with the health authority and reviewed quarterly reports in accordance with 103 CMR 932.01(3).

Initial Medical Screenings and Health Assessments

We determined whether HSO provided its inmates with initial medical screenings upon admission and health assessments within 7 days (or 14 in certain cases) in accordance with 103 CMR 932.06 and 932.07. To do this, we selected a nonstatistical, random sample of 60 inmates out of the total population of 811 who were admitted to the Hampshire Sheriff’s Office Jail and House of Correction (HJHC) during the audit period. We excluded regionally arrested individuals because they are not required to have initial medical screenings or health assessments. We performed the following procedures:

• We examined the initial medical screening form for each inmate in our sample to verify that an in-house healthcare employee recorded the completion date. We also verified that the health authority signed each screening form, as required by 103 CMR 932.06. We then compared the date of the inmate’s admission to HJHC to the date the initial medical screening was completed to determine whether each inmate received the initial medical screening upon admission.
• We examined the health assessment form(s) for each inmate in our sample to verify that an in‑house healthcare employee recorded the completion date and signed the forms. We then compared the date of the inmate’s admission to HJHC to the date the health assessment was completed to determine whether each inmate received the health assessment within 7 days (or extended to 14 days in certain cases), as required by 103 CMR 932.07.

We used nonstatistical sampling methods for testing and therefore did not project the results of our testing to any population. See Finding 1 for an issue we identified related to HSO’s initial medical screenings.

Sick Call Requests

To determine whether (1) inmates received medical care after they submitted a sick call request form in accordance with HSO’s Policy 4.3.2 and (2) HSO documented the medical care its inmates received in accordance with 103 CMR 932.18(2)(h) and (k), we selected a nonstatistical, random sample of 60 out of the population of 783 sick call request forms that were submitted by inmates during the audit period. For our sample, we performed the following procedures:

• We examined each sick call request form to verify that inmates included all pertinent information and that an in-house healthcare employee recorded the completion date.
• We examined each sick call request form, medical file, and/or sick call medical note to determine whether an in-house healthcare employee completed a face-to-face meeting and recorded the date of the face-to-face meeting.
• We examined each sick call request form, triage record in the Correctional Electronic Medical Records (CorEMR) system, and/or sick call medical note to determine whether an in-house healthcare employee (1) reviewed the sick call request form for the immediacy of need, (2) documented and attached the suggested treatment to the inmate’s triage record in the CorEMR system, and (3) referred problems beyond their scope to the appropriate contracted healthcare provider.

We used nonstatistical sampling methods for testing and therefore did not project the results of our testing to any population.

We noted no exceptions in our testing; therefore, we determined that inmates received medical care after they submitted sick call request forms in accordance with HSO’s Policy 4.3.2 and that HSO documented the medical care its inmates received in accordance with 103 CMR 932.18(2)(h) and (k).

Data Reliability Assessment

Offender Management System

To assess the reliability of the inmate data that we obtained from the Offender Management System (OMS), we interviewed HSO’s information technology employees who oversaw the system. We tested general information technology controls (e.g., access and security management controls). We selected a random sample of 20 inmates from the list of inmates in OMS and compared the inmates’ information from this list (full name, date of birth, booking date, sex, age, race, and facility) to the information in the original source document (the mittimus) for agreement.

We selected a random sample of 20 hard copies of the mittimuses and compared the inmates’ information from the mittimuses (full name, date of birth, and commitment date) to the information in the list of inmates in OMS for agreement. In addition, we tested the data for the population of 811 inmates for duplicate records. We reconciled the list of in-custody deaths from OMS with the list provided to us by the Office of the Chief Medical Examiner.

Based on the results of the data reliability procedures described above, we determined that the OMS data were sufficiently reliable for the purposes of our audit.

CorEMR System

We assessed the reliability of the sick call list that we obtained from the CorEMR system by conducting interviews with HSO officials who were knowledgeable about the list. We tested general information technology controls (e.g., access and security management controls). In addition, we tested the sick call list from the CorEMR system for any worksheet errors (hidden objects such as rows, headers, and other content). Additionally, we matched the inmate information in the sick call list from the CorEMR system to the list of inmates booked during the audit period from OMS to summarize the number of sick calls to the inmates’ commitment dates, dates of birth, and dates of request.

To confirm the completeness and accuracy of the sick call list in the CorEMR system, we selected a random sample of 20 records in the sick call list in the CorEMR system and compared, for agreement, the information on the list (the inmate’s patient identification number, their full name, the date of the sick call request, the inmate’s signature, and the date of service provided by the in-house healthcare employee) to the information on the hard copies of the sick call request forms submitted by inmates. We also selected a random sample of 20 hard copies of the sick call request forms and traced the information on the forms (i.e., full name and date of the sick call request) back to the data in the sick call list in the CorEMR system.

Based on the results of the data reliability procedures described above, we determined that the CorEMR system data were sufficiently reliable for the purposes of our audit.

Date published:	November 16, 2023