Report 2013-120 Recommendation 11 Responses

Report 2013-120: Sterilization of Female Inmates: Some Inmates Were Sterilized Unlawfully, and Safeguards Designed to Limit Occurrences of the Procedure Failed (Release Date: June 2014)

Recommendation #11 To: Correctional Health Care Services, California

To ensure that inmates receive only medical services that are authorized through its utilization management process, the Receiver's Office should ensure that the computer system it procures includes functionality to electronically link medical scheduling with authorization through the utilization management process to prevent all unauthorized procedures, regardless of whether they may result in sterilization, from being scheduled.

Annual Follow-Up Agency Response From October 2019

The California Correctional Health Care Services (CCHCS) has implemented a mechanism to electronically link medical scheduling with authorization through the utilization management process to prevent all unauthorized procedures that may result in sterilization. The health care provider cannot refer a patient directly to an outside entity for procedures that would lead to loss of fertility. The electronic health record system routes requests for these types of high risk procedures through a utilization management process for secondary review and then ultimately by a CCHCS headquarters review committee.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented


Annual Follow-Up Agency Response From November 2018

The response remains unchanged from last year: The California Correctional Health Care Services (CCHCS) has implemented tracking mechanisms to identify patients who need procedures that may result in sterilization. In addition, a monthly review of the claims payment system has shown that each relevant case has been reviewed and approved by Utilization Management Staff. These processes have proved effective. Further, the statewide rollout of the Electronic Health Records System (EHRS) was completed in October 2017. To supplement existing safeguards, CCHCS will leverage the functionality of the EHRS to identify these patients, rather than procure a separate new system. CCHCS is pursuing a change order to be added to the existing EHRS enhancement queue and should have a solution by the end of 2019.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From November 2017

The California Correctional Health Care Services (CCHCS) has implemented tracking mechanisms to identify patients who need procedures that may result in sterilization. In addition, a monthly review of the claims payment system has shown that each relevant case has been reviewed and approved by Utilization Management Staff. These processes have proved effective. Further, the statewide rollout of the Electronic Health Records System (EHRS) was completed in October 2017. To supplement existing safeguards, CCHCS will leverage the functionality of the EHRS to identify these patients, rather than procure a separate new system. CCHCS is pursuing a change order to be added to the existing EHRS enhancement queue and should have a solution by the end of 2019.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2016

The California Correctional Health Care Services (CCHCS) entered into a contract with Health Net Federal Services (HNFS) in October 2014 to procure an electronic Prior Authorization System. This system was due to be implemented no later than August 2015. After numerous attempts to deploy the system, it remained unstable and ultimately unusable. CCHCS did not reimburse HNFS for this failed application and intends to revisit procuring a system after the statewide rollout of the Electronic Health Records System (EHRS). Staff are researching a possible flag in the EHRS system to identify these cases on a real time basis. In the meantime, all non-emergent referrals for services that may result in sterilization are reviewed by the Headquarters Utilization Management Committee monthly. Additionally, provider claims and the Interqual decision support tool are reviewed to ensure no referral has bypassed the process.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented


Annual Follow-Up Agency Response From October 2015

California Correctional Health Care Services procured an electronic prior authorization system, which is on schedule to be fully implemented and operational by December 2015. This system will require that all procedures that may directly or indirectly result in sterilization be authorized by the Utilization Management executives.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented


1-Year Agency Response

California Correctional Health Care Services procured an electronic prior authorization system, which should be fully implemented and operational in December 2015, to allow staff access and link medical scheduling, in real time, with authorization through the utilization process.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

On November 3, 2014, the contract was awarded and Utilization Management is currently working with the contractor in constructing a system that has the capacity to flag procedures requiring authorization and preventing them from being scheduled, regardless of whether the procedure results in sterilization.

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Proposed Action Plan:

Procure an electronic prior authorization system.

Status/Comments:

California Correctional Health Care Services is in the process of procuring an electronic prior authorization system which should be fully implemented one year after the contract is awarded. This system will require that all procedures that may directly or indirectly result in sterilization be authorized by the Utilization Management executives.

California State Auditor's Assessment of 60-Day Status: Pending


All Recommendations in 2013-120

Agency responses received are posted verbatim.