Overview
SCSD did not ensure that its healthcare vendor complied with all the service delivery and documentation requirements of SCSD’s Policy S604 (Inmate Care and Treatment) regarding sick calls. Specifically, in our review of a statistical sample of 60 Health Service Request Forms (HSRFs) from a population of 5,664 HSRFs submitted by inmates between March 1, 2021 and June 30, 2021, we found that 4 HSRFs were not triaged by a healthcare staff member within 24 hours. Four of the 56 HSRFs that were triaged within 24 hours described clinical symptoms,19 but the inmates who submitted the forms did not have face-to-face encounters with healthcare staff members within 48 hours (on weekdays) or 72 hours (on weekends) upon receipt of a sick call.
In addition, we found numerous issues with qualified healthcare professionals’ documentation of the information on the some of the HSRFs we sampled. For example, 13 HSRFs did not indicate the date they were received, 18 HSRFs did not indicate a triage date, 23 HSRFs did not indicate the immediacy of need for treatment, and 4 HSRFs did not indicate suggested treatment.
Because SCSD does not ensure that its healthcare vendor provides all the sick-call-related healthcare required by SCSD policy and documents all required information on HSRFs, there is a higher-than-acceptable risk that some inmates may not have their healthcare issues properly resolved.
Authoritative Guidance
Section 7 of SCSD’s Policy S604 (Inmate Care and Treatment) states,
B. Sick call requests shall be documented and reviewed for immediacy of need and required intervention. . . .
F. Inmates shall submit the request by placing it in a secure box in the housing unit, from where it shall be picked up daily by medical staff and triaged within twenty-four (24) hours.
G. When a request describes a clinical symptom, a face-to-face encounter between the inmate and medical staff must occur within forty-eight (48) hours during the week and seventy-two (72) hours on weekends.
H. Medical staff will evaluate, triage, and suggest treatment, and refer problems beyond their scope to the appropriate provider.
Regarding HSRFs, 103 CMR 932.18(2) states, “The medical record file shall contain, but not be limited to . . . place, date and time of health encounters.”
The HSRF indicates that the information detailed in 103 CMR 932.18(2) must be documented on the HSRF, as well as other information, such as the date the HSRF was filed and the date it was triaged.
Reasons for Noncompliance
SCSD management stated that during the audit period, the department’s healthcare vendor had staffing problems due to the 2019 coronavirus pandemic. SCSD has not established any monitoring controls (i.e., policies and procedures) over its sick call process to ensure that its healthcare vendor complies with all the requirements of SCSD’s healthcare policies.
Recommendation
SCSD should establish monitoring controls (i.e., policies and procedures) over its sick call process to ensure that its healthcare vendor complies with all the requirements of SCSD’s healthcare policies.
Auditee’s Response
The Department acknowledges that Wellpath did not comply with all of the requirements of its sick call policy, and this was a major reason that the Department terminated its contract with Wellpath.
While the Department recognizes Wellpath’s failures in this area, the Department vehemently disputes that it lacks monitoring controls in place to adequately monitor the healthcare vendor's compliance. The Department detailed to the auditors Wellpath’s failure to meet the staffing and the onsite supervision requirements of the contract. As a result, Wellpath was unable to adequately resolve the compliance issues the Department regularly raised in our weekly meetings and calls. Because of these breaches and the Department’s concern that these failings could negatively impact the care provided to the inmates, the Department terminated the contract with Wellpath and replaced them with another healthcare vendor.
The Department employs a medical professional with prior Health Services Administrator experience in a correctional setting to closely supervise the current medical vendor and ensure the safe administration of care to the inmates and to ensure the vendor’s compliance with the terms of the contract. The issues that the auditors detailed with Wellpath were consistent with the failings the Department observed, raised, and discussed regularly with the vendor. Because the issues continued and were not sufficiently addressed by Wellpath, the Department notified Wellpath of their breach, prior to the onset of the Audit. The Department took swift and decisive action to terminate the contract when faced with the failings of Wellpath to meet its statutory and contractual obligations, and this action belies the Audit’s finding that the Department somehow had insufficient monitoring tools to recognize these failings of the vendor.
Auditor’s Reply
As noted above, we found that during our audit period, SCSD did not ensure that its healthcare vendor complied with all the service delivery and documentation requirements of SCSD’s Policy S604 regarding sick calls. OSA acknowledges that SCSD staff members were aware of and attempted to address various issues with its healthcare provider’s administration of its sick call process, which we believe was prudent. However, we found that SCSD has not established any formal monitoring controls (i.e., policies and procedures) over its sick call process to ensure that its healthcare vendor complies with all the requirements of SCSD’s healthcare policies. In OSA’s opinion, having formal monitoring controls documented in agency policies and procedures would have provided SCSD with a means to more consistently and effectively detect, document, and address any issues of noncompliance by its healthcare vendor in an expeditious manner.
| Date published: | December 7, 2022 |
|---|