Overview
During the audit period, Sick Call Request Forms (SCRFs) were not processed or triaged within 24 hours (72 on weekends)4 and/or were not completely filled out by nurses and/or physicians, and inmates were not always seen by a qualified healthcare professional (QHP) within seven days after they submitted SCRFs. Without timely treatment for physical and mental health issues, an inmate’s condition could worsen. Additionally, the Department of Correction (DOC) puts itself at risk of legal action by not documenting that SCRFs are triaged and inmates are seen promptly.
Although we found that all 60 inmates in our sample were seen by a QHP, DOC did not process and triage the SCRFs promptly. For 18 of 60 inmate medical files tested, SCRFs were processed and triaged 1 to 31 days late. We identified 55 SCRFs with this issue out of 297 SCRFs maintained in the 18 inmate medical files. Of the 55 SCRFs, 28 did not have a date from the triage nurse or the inmate, so we could not determine whether the inmate was seen by a triage nurse within the required time.
There were portions of the SCRFs that were not filled out in their entirety, by nurses and/or physicians, for 23 of 60 inmate medical files tested. Within the 23 files were a total of 363 SCRFs, 163 of which were missing information: 33 did not have a referral to a medical professional, 102 did not have a nurse triage determination, and 28 did not indicate the institution where the inmate was housed.
Finally, for 19 of 60 inmate medical files tested, there was no evidence that the inmates were seen by QHPs within seven days after they submitted SCRFs. We identified 72 SCRFs with issues out of 302 SCRFs in the 19 files. Of the 72 SCRFs, 33 did not have a date from a QHP or the inmate, so we could not determine whether the inmates were seen within seven days by a QHP. Additionally, 38 SCRFs had instances where an inmate was seen more than seven days after submission of the SCRF, and in 1 case, the date recorded by the QHP was one day before the date recorded by the inmate.
Authoritative Guidance
In regard to SCRFs being processed and triaged and the inmates being seen by QHPs promptly, Section 10(4) of DOC policy “103 DOC 630—Medical Services” states,
All requests must be processed and triaged by a qualified healthcare professional within twenty-four (24) hours or seventy-two (72) on week-ends. All inmates who submit a sick call request shall be seen by a qualified healthcare professional on a priority basis that will not exceed seven (7) calendar days from the day of submission of the request.
In regard to SCRFs being filled out entirely and signed by DOC representation, Section 761.07(7) of Title 103 of the Code of Massachusetts Regulations states,
Requests for medical attention shall be assessed and processed in accordance with guidelines established by the National Commission on Correctional Health Care and according to American Correctional Association standards and Department guidelines.
The National Commission on Correctional Health Care publication Standards for Health Services in Prisons recommends that “all aspects of the health care request process, from review and prioritization to subsequent encounter, [be] documented, dated, and timed.”
Reasons for Issues
DOC officials could not provide us with a reason for these issues at the time of our audit. However, we did note that controls over the administration of these activities appeared to be deficient.
Recommendation
DOC should ensure that there are internal controls and monitoring in place to ensure compliance with DOC policies and procedures.
Auditee’s Response
The Department of Correction (DOC) received and reviewed the list of examples of concern raised by the Auditor’s findings. The Health Services Division (HSD) pulled each inmate medical file and identified the issues corresponding to the Auditor’s findings.
The DOC HSD appreciates the external review and feedback for the Sick Call process and policy. As a result of your findings, the DOC has identified an opportunity for improvement which is addressed here. We recognize this is a collaborative and constructive process which affords the DOC an opportunity to improve on existing process and policies to more effectively deliver equitable access to quality healthcare for every inmate.
SCRF not processed or triaged within 24 hours (72 on weekends)
In a subsequent review of the files, HSD found discrepancies between the date of submission as written by the inmate and the date the SCRF was received in the Health Services Unit (HSU) at the site. The standard practice for the DOC is to use the date of receipt by the HSU. When the SCRF is retrieved, the QHP is required to stamp or indicate on the form when it was received. This is the date used to document the timeliness of service. In several cases, the auditors identified the date that the inmate denoted on the form. However, this date is not always the date the SCRF is actually submitted.
In some instances, the inmate may inadvertently use the incorrect date. In some instances, the inmate incorrectly post-dates the SCRF. In some instances, the inmate may not submit the form on the same day that the inmate fills it out. Therefore, to ensure more consistency with dates, the HSD has opted to use the date the SCRF is received by HSU.
SCRF not completely filled out by nurses or physicians
HSD reviewed the forms and agrees with the Auditor’s findings. The forms have several check boxes to provide basic information regarding the SCRF request including, but not limited to: date/time triaged, acuity of request, facility, and specialty. HSD did review the medical record of those individuals and did not find any instance where an incomplete SCRF resulted in untimely response to urgent or emergent issues. HSD recognizes the importance of fully completing all required fields on the SCRF. HSD will work with its contracted healthcare vendor to reinforce the requirement that all fields must be completed.
Inmates were not always seen by a qualified health professional within 7 days after SCRF submission
HSD identified several SCRFs which were administrative in nature. For example, there were requests for replacement hearing aid batteries, repair to eyeglasses, or asking for HIV/Hepatitis C testing. These are examples of administrative requests which would not require the inmate to see a QHP for care. Instead, these issues were responded to by providing the requested supplies or repairs, or referring the SCRF to a counselor for the requested testing. The sick call process is the most common avenue inmates have to bring these issues to the attention of the medical provider. However, the SCRF policy language does not account for these types of administrative requests. Therefore, the DOC will review the policy and revise the language to differentiate between the services which may, or may not, require clinical assessment within the current policy timeframes.
Auditor’s Reply
Regarding the processing of SCRFs, for our analysis we used the date of submission indicated on the SCRF to conduct our analysis because this form is the official record used by the agency to document the need for medical services requested by an inmate in accordance with DOC policy. We recognize that inmates may sometimes enter erroneous dates on SCRFs. However, since the extent to which errors like this may have occurred in our sample could not be reasonably determined by us or by DOC, it was necessary and reasonable for us to rely on the accuracy of the submission dates on the SCRFs to assess DOC’s compliance with its requirements in this area. It should be noted that, even using the date stamp as the official date of receipt as DOC suggests, our analysis still showed a significant number of instances where DOC did not meet its processing timelines.
Based on its response, DOC is taking measures to clarify existing policies and ensure that they are consistently applied throughout all its facilities.
| Date published: | January 9, 2020 |
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