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Recommendations

2023-110 California Department of Public Health

Process Improvements Could Help Reduce Delays in Completing Fetal Death Registrations

Audit Recommendations Disclosure

When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor’s assessment of auditee’s response based on our review of the supporting documentation.

Recommendations for Legislative Action

Recommendation 1

To improve the average time it takes for fetal death registration statewide, the Legislature should amend state law to require hospitals, or any medical facilities where fetal deaths may occur, to initiate the creation of the fetal death certificate for any fetal deaths that occur at their facilities. In doing so, the Legislature should reaffirm that physicians, or hospital staff as their delegates, are responsible for entering the required medical information into the fetal death certificates and should clarify that physicians must sign the certificates before transferring responsibility for the next steps of certificate completion to funeral homes.

Status

pending

Recommendation 2

To ensure the effective enforcement of fetal death registration timeliness requirements, the Legislature should amend state law to require CDPH to regularly notify the Medical Board, the Funeral Bureau, and any other relevant licensing entity, such as the Osteopathic Medical Board, of instances in which registration data indicate that physicians or funeral establishments are repeatedly failing to comply with these requirements. The notification should include the information necessary for the licensing entity to adequately investigate delinquent fetal death registrations.

Status

pending

Recommendations to Dept. of Public Health

Recommendation 3

To reduce the time that parties involved in the fetal death registration process take to notify one another that a certificate is pending action, CDPH should, by June 2024, submit a request to its registration system vendor to develop and implement in the system an electronic notification mechanism that will alert the appropriate user outside the system, such as by email, that a certificate is awaiting that user’s action.

Status

Fully implemented

Date of implementation

January 2024

60-Day Agency Response

CDPH Vital Records (VR) completed this recommendation and has already submitted a change request as part of the new scope of work for the registration system vendor to develop an electronic notification mechanism. (See Project Summary and Scope of Work.pdf) VR will be taking this recommendation further by working with staff and the vendor on the next stages to fully execute and implement this change request once the new contract is in place.

Evaluator Assessment Status and Public Reasoning

Pending. Department did not substantiate its claim of full implementation

As part of the new scope of work for its registration system, CDPH has submitted a change request to the registration system vendor to develop an electronic notification mechanism. Although CDPH states the scope of work has been vetted and approved by CDPH internal leadership and the registration system vendor, the scope of work is still under review by the California Department of Technology. As such, we conclude this recommendation is partially implemented. Once the updated scope of work is finalized, we will again assess the status of the recommendation.

Recommendation 4

To better fulfill its duty to oversee the fetal death registration process, CDPH should, by June 2024, begin to hold meetings regularly with local registrars to identify and resolve issues related to fetal death registration. CDPH should include in such meetings representatives for parties involved in the registration process—such as hospitals, physicians, and funeral homes—as well as representatives from relevant licensing entities—such as the Medical Board and the Funeral Bureau—to obtain additional perspectives about ongoing causes for delays.

Status

Not fully implemented

Date of implementation

June 2024

60-Day Agency Response

CDPH Vital Records (VR) currently holds quarterly meetings (Quarterly Local Jurisdiction Meeting) where stakeholders are invited to ask questions and discuss vital records topics, including the fetal death registration process. VR is planning on scheduling regular meetings specific to the fetal death registration process, for narrower group of stakeholders (e.g. fetal death registration system users, representatives of Medical Board, Cemetery and Funeral Bureau) to discuss issues at a more granular level. VR intends to gather input from stakeholders to determine discussion topics and establish agendas for each meeting. VR will consider the topics submitted and provide guidance during the meeting. Stakeholders will have the opportunity to ask questions and request clarification on the topics discussed.

Recommendation 5

To better ensure the effectiveness of its help desk, CDPH should, beginning in June 2024, periodically survey local registrars to solicit feedback on their experience with the help desk and should use this feedback to improve help desk processes as necessary.

Status

Not fully implemented

Date of implementation

June 2024

60-Day Agency Response

CDPH Vital Records will create a survey for local registrar staff to provide feedback and suggestions, aiming to enhance the effectiveness of help desk support and improve the user experience for all registration system users. The survey will be created and sent to local registrar staff no later than June 2024.

Recommendation 6

To mitigate registration delays and ensure that all hospitals and funeral homes with a responsibility to complete their portions of fetal death certificates are able to rapidly fulfill their obligations, CDPH should, by June 2024, notify hospitals and funeral homes that lack access to its registration system for fetal deaths of their legal obligations in the fetal death registration process and provide instructions on how to access the data system used to fulfill those obligations.

Status

Not fully implemented

Date of implementation

June 2024

60-Day Agency Response

CDPH Vital Records (VR) staff plan to reconcile the user lists of the electronic fetal death registration system, funeral home, and medical facilities with the lists of licensed facilities in California. This process aims to identify organizations not currently using the electronic system for fetal death registration and encourage their participation. VR will notify the identified organization of their statutory responsibilities regarding fetal death registration, and the availability and advantages of electronic registration to meet those responsibilities, including instructions on how to gain access to the electronic registration system and provide training for their staff.

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