NCCHC's New Standards and the Role of the Physicia

By Dianne Rechtine, MD, CCHP-A

Posted on September 8, 2008 – NCCHC recently published new editions of the Standards for Health Services for both jails and prisons. The 2008 Standards emphasize quality of care for inmate-patients, and chart reviews by physician surveyors will focus on the actual care delivered to the patient. This article focuses on new and revised standards with implications for the role of the physician.

Patient Safety requires patient safety systems to prevent adverse and near-miss clinical events. There should be an error reporting system for health care staff to voluntarily report, in a nonpunitive environment, errors that affect patient safety.

Continuous Quality Improvement now requires that every facility regardless of size will do at least one process study and one outcome study every year. Those facilities with an ADP of 500 or more will be required to perform two process studies and two outcome studies each year. Process studies examine the effectiveness of the health care delivery process. Outcome quality improvement studies examine whether expected outcomes of patient care were achieved. The responsible physician is involved in the processes of the CQI program by identifying thresholds, interpreting data, and solving problems. Clinician chart review has been moved to the Continuity of Care During Incarceration standard.

Procedure in the Event of an Inmate Death now states that the death review consists of an administrative review, a clinical mortality review, and a psychological autopsy if death is by suicide.

Professional Development requires that health care professionals participate annually in continuing education annually. The 2008 standards allow compliance to be demonstrated through one of the following: in States where at least 12 hours of continuing education is required annually to maintain a clinical license to practice, a current license suffices; and when the health staff is a Certified Correctional Health Professional (CCHP), valid certification suffices.

Initial Health Assessment has two options for implementing and demonstrating compliance with this standard. The first option is the Full Population Assessment and involves performing the health assessment on 100% of the inmates coming to a prison within 7 days and 100% of the inmates remaining in the jail within 14 days. This health assessment may be performed by properly trained RN’s (whose assessments must be cosigned by the physician) or performed by midlevel practitioners whose assessments are reviewed by the physician if significant findings are present. The Individual Assessment When Clinically Indicated involves performing assessments only on those at high risk for clinically significant findings. This assessment should be done as soon as possible, but no later than 2 working days after admission. To qualify for the second option, an institution must have 24-hour/7 day on-site health coverage; allow only licensed health care personnel to conduct a comprehensive receiving screening which includes further inquiry into past history and symptoms of chronic diseases, finger stick glucose on individuals with history of diabetes, vital signs to include blood pressure, and further inquiry into medication and dosages where possible. This health assessment may only be performed by midlevel practitioners or physicians. The responsible physician documents his review of other clinicians’ significant findings.

Continuity of Care During Incarceration specifically requires evidence in the medical record of the clinician’s review of results of diagnostic tests, emergency visits, specialist care, and hospital discharge summaries and requires that the results have been reviewed with the patient in a timely manner.

Chronic Disease Services requires that patients identified with chronic diseases are enrolled in a chronic disease program. The responsible physician establishes and annually approves clinical protocols consistent with national clinical practice guidelines. Documentation in the medical chart confirms that clinicians are following chronic disease protocols and/or clinically justify any deviation from the protocol. As part of the accreditation process, physician surveyors will utilize specific audit sheets for each chronic clinic. The audit sheets will have compliance indicators representing the nationally recognized clinical guidelines.

Patients with Special Health Needs requires individualized treatment plans be developed by a physician or other qualified clinician at the time the condition is identified and updated when warranted.

Suicide Prevention Program includes a requirement for a treatment plan be developed that addresses suicidal ideation and its reoccurrence and that patient follow up occurs as clinically indicated.

Dr. Rechtine is an SCP member and active NCCHC physician surveyor. Readers may contact her at drechtine@pol.net.
Copies of NCCHC’s 2008 Standards are available for purchase on their Web site at www.ncchc.org.