Kathleen Bachmeier ACA Office of Correctional Health Care Health Care Specialist email@example.com 703-224-0076
Health Care Auditor Expectations • Act as the “eyes and ears” of the Commission on Accreditation for Corrections (CAC) • You are the expert from the field of correctional health on the audit team • The goal of the health care auditor is to assist the facility in attaining ACA accreditation.
Health Care Auditor Expectations • Auditors should complete the file folders for all mandatory standards prior to examining those of non-mandatory standards • All standards found in non-compliance and/or non-applicability need to be discussed with chair and other member of the audit team before signing the folder
Health Care Auditor Expectations • Health care auditors should know thoroughly and completely the health care standards and other standards that they may be assigned to review. In the ACI manual, there are 29 mandatory standards in health care section. In the ALDF manual, the health care section has 25 mandatory standards. • Some health care standards have bullets. Each bullet should have supporting documentation.
Health Care Auditor Expectations • Auditors should avoid projecting their own experience or biases. Auditors should look through the eyes of the facility and how they are interpreting the standard. • When a red flag arises regarding a standard and/or the facility’s implementation of the standard, ask the question: What is the intent of the standard? • Health Care auditors should use the facility tour to see the standards in practice and is an opportunity to ask questions regarding health care standards to line staff
Health Care Auditor Expectations • Health Care auditors should use the facility tour to see the standards in practice and is an opportunity to ask questions regarding health care standards to line staff • Be timely • Be engaged and follow the audit chair’s lead. • Respect audit chair and other member of the team.
Health Care Auditor Expectations • Health care auditors should interview facility staff and inmates • Dress professionally. Remember that you are representing ACA, the Commission on Accreditation, and the field of correctional health care.
Health Care Auditor Expectations • The chair will ask you to write a brief report. The report should reflect conditions of confinement from health care perspective and any issues regarding the facilities overall application of the health care standards
Questions for the Facility Tour A few carefully thought-out questions asked of facility staff and managers can provide insight into daily practices. Some such questions are: 1. How do you handle bio-hazardous waste? 2. How do you handle medical or dental instruments after they have been used on an inmate? 3. Please explain to me your TB surveillance program.
Questions for the Facility Tour 4. How is an inmate medical emergency handled? Dental emergency? 5. How does an inmate find out about how to access the grievance system? 6. What is the process for an inmate to access health serves? Does it work?
During file review… • Questions regarding how a standard is interpreted need to be addressed and discussed with audit chair and with ACA Standards Specialists (if necessary) prior to discussion with the facility.
Standards Interpretations/Definitions: “Upon Arrival” • ACI 4-4362: “commences upon the offenders arrival at the facility” (pertains to medical screening) • ACI 4-4363: “commences on their arrival at the facility” (pertains to intrasystem transfers) • ACI 4-4370: “An initial mental health screening at the time of admission to the facility” • 4-ACRS-4C-06: “Medical, dental, mental health screening by health trained or qualified health-care personnel on all offenders upon arrival at the facility”
Standards Interpretations/Definitions: “Upon Arrival” • “Upon Arrival” is defined by ACA as requiring that the mandated actions are undertaken as part of the booking or admission of an inmate to the facility. This means that these actions are done prior to the assignment of housing. • The intent of screening “upon arrival” is to ensure inmateand facility safety and security. This screening protects the facility by ensuring that the inmate has no medical, mental health, or dental issues that need to be addressed immediately. • Those completing the screening should ask: Can this inmate be admitted safely to the facility?
Standards Interpretations/Definitions: Health Authority ACA defines the “Health Authority” as: “The health administrator, or agency responsible for the provision of health care services at an institution or system of institutions; the responsible physician may be the health authority.” • Adult Local Detention Facilities, 4th Edition Page 177
Standards Interpretations/Definitions: Health-trained personnel/Medically-trained personnel ACA defines these personnel as: “Correctional officers or other correctional personnel who may be trained and appropriately supervised to carry out specific duties with regards to administration of health care.”
Standards Interpretations/Definitions: Health-trained personnel/Medically-trained personnel • Health care personnel (Qualified medical person): Individuals whose primary duty is to provide health services to juveniles or inmates in keeping with their respective levels of health care training and experience.
Standards Interpretations/Definitions: Health-trained personnel/Medically-trained personnel • Health care practitioner: Clinicians trained to diagnosis and treat patients, such as physicians, dentists psychologists, podiatrists, optometrists, nurse practitioners and physician assistants.
Standards Interpretations/Definitions: Qualified Health Care Personnel • Qualified health care personnel (Qualified medical person): An individual who has education, credentials, and experience and is permitted by law within the scope of his or her professional practice act, to evaluate and care for patients.
Standards Interpretations/Definitions: Health Care Screenings • The purpose of a screening is to determine whether the inmate has any disease, illness or condition that precludes admission to the facility. • The health care auditor should familiarize themselves with the facility’s booking/admission process. It is the health care auditors job to determine if the required screenings are taking place at an appropriate time (during the intake process and before the assignment of housing)
Standards Interpretations/Definitions: Health Care Screenings Health care auditors should also ask… • When is the medical department alerted as to the need for further evaluation of offender medical needs? • Does facility documentation show timely and complete screenings of incoming inmates? • Does the timing of the screening make sense with the size, layout, and type of facility? (For example, larger facilities will have longer waits for screenings than will smaller facilities)
Standards Interpretations/Definitions: Health Care Screenings • Auditor needs to verify that the procedures for health screening protocols were established by the designated Health Authority. • Documentation in written policies and procedures or protocols should reflect approval of health screenings by the designated Health Authority. • To ensure compliance with screenings “upon arrival”, the auditor can check facility transfer logs.
Standards Interpretations/Definitions: Health Appraisals • The Health Appraisal is the systematic gathering of inmate health information by a qualified health care personnel. • Both the ACI and ALDF manuals mandate that health and mental health appraisals take place with within 14 days of arrival.
Standards Interpretations/Definitions: Medical Examinations In the ACI manual… • Inmate with a significant health care problem has a medical examination within 14 days. • Inmate without significant health care problem has a medical examination within 30 days • 14 days after an referral for mental health treatment, inmates are to receive a comprehensive evaluation. In the ACRS manual... • Each newly admitted resident who was not transferred from a correctional facility undergoes a medical examination within 14 days of admission.
Standards Interpretations/Definitions: Medical Examinations In the ALDF manual... • Comprehensive mental health evaluation is required after a referral for mental health treatment within 14 days. • Within 30 days of arrival, inmates identified as having significant health problems will receive a medical examination. • Clinical dental examination by a dentist within 12 months of admission.
Standards Interpretations/Definitions: Direct care staff ACA defines “Direct Care Staff” as: “Any staff member who routinely has contact with the inmate or juvenile population.”
Standards Interpretations/Definitions: Intersystem and Intra-system Transfers • Intersystem transfers are transferred inmates from one distinct correctional system to another. • Intra-system transfers are inmates transferred from facility to facility within a correctional system.
Standards Interpretations/Definitions: Syringe • A syringe consists of a barrel, plunger and/or a needle. • Any parts of a syringe are to be counted, controlled and inventoried. • Medical and dental instruments and supplies (which include the syringes, needles, and syringes without needles [barrel and plungers]) that are stocked for daily use are inventoried, controlled, and counted daily, at a minimum. • A perpetual inventory of bulk stock needles, syringes, syringe parts, blades, and other sharps are maintained in a locked storage area.
Standards Interpretations/Definitions: Syringe When items are identified as having the potential to causing harm to an inmate or staff, such items must be inventoried and controlled. Needles, syringes, blades and other sharps are considered contraband in the correctional setting.
Standards Interpretations/Definitions: What is an infirmary? • An infirmary is a specific area within an institution, separate from other housing areas, where offenders are admitted for health observation and care under the supervision and direction of health care staff. • Admissions and discharge from this area is controlled by medical orders or protocols.
Standards Interpretations/Definitions: Infirmaries: ACI 4-4253 Onsite infirmaries include, at a minimum: • a defined scope of available infirmary care • a physician on call 24-hours/day. • health care personnel have access a physician or RN and are on duty 24-hours per day when patients present. • inmates with in sight and sound of a staff member. • an infirmary care manual. • compliance with applicable state statues and local licensing requirements.
Standards Interpretations/Definitions: Segregation • ACI 4-4400 MANDATORY (Revised January 2006): When an offender is transferred to segregation, health care staff will be informed immediately and will provide a screening and review as indicated by the protocols established by the health authority. Unless medical attention is needed more frequently, each offender in segregation receives a daily visit from a qualified health care professional. The visit ensures that offenders have access to the health care system. The presence of a health care provider in segregation is announced and recorded. The frequency of physician visits to segregation units is determined by the health authority.
Standards Interpretations/Definitions: Peer review ACI 4-4411 (Revised January 2006) • A documented review program for all health care practitioners and a documented external peer review program will be utilized for all physicians, psychologists and dentists every two years. • The credentialing and privileging process is an integral part of assuring the compliance of the providers for the inmate patients they treat. • Peer review should be routine every two years with the ability to have an immediate review if problems arise.
Standards Interpretations/Definitions: Peer review • The responsible physician should receive the report, take action, and be prepared to demonstrate to the auditors, within the confines of confidentiality, the process, process indicators, and actions available. • It is important that the auditors appreciate that the process is real and meaningful and that peer review is not simply a paper trail.
Standards Interpretations/Definitions: Peer review • Documentation in folders should show peer review program for all health care practitioners exists. • Documentation of outside peer review program every two years is required for physicians, psychologists and dentists.
Standards Interpretations/Definitions: Peer review • The intent of the peer review standard is to have knowledge experts of equal or higher degreed discipline practitioners review each other’s day to day work for appropriateness of the health care delivered to inmates. The outside peer review exists to ensure that physicians, psychologists and dental practices meet the expectations of those professionals in the community. • The best practice would be that the outside peer review suggestions , recommendations or approvals are accepted or followed –up as appropriate per facility peer review process.
I do the very best I know how, The very best I can; And mean to keep on doing it till the end. Nearly all men can stand adversity, But if you want to test a man’s character, Give him power. -Abraham Lincoln