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February 9, 2017

Mr. Lee Smith


Chatham County Manager
124 Bull Street, Suite 220
Savannah, Georgia 31401

Dear Mr. Smith:

At your request, this letter reports the outcome of COCHS findings to date with regard to
CorrectHealth contract compliance, specifically, those critical issues impacting inmate safety.
Additionally, this letter reports the outcome of COCHS' review of the amount of money
CorrectHealth owes the County for penalties under the contract dated September 1, 2016. This
letter covers the period from November 1, 2016, to January 31, 2017.

I. Findings to Date
COCHS has routinely visited the Chatham County Detention Center (CCDC) since the
implementation of the CorrectHealth contract to monitor and gather information about
contract compliance and service delivery. While COCHS has seen some improvements in
policies and procedures, staffing, and services, critical areas warrant attention and remediation.
These include CorrectHealths:

Failure to develop timely policies and procedures


To date, CorrectHealth has failed to develop and implement adequate policies and procedures
that would meet accreditation standards. While COCHS has been provided draft policies from
CorrectHealth, we are still in an iterative stage of revisions with CorrectHealth on this process.
The lack of consistent policies and procedures is most evident through discussions with staff in
the areas of mental health. While improvements have been made in the areas of suicide
prevention observation and medication administration, there are numerous other instances
where a lack of clear policy and procedure is increasing the likelihood of an adverse event. By
this point in the contract we would expect that a robust and adequate set of policies and
procedures are not only developed, but that staff are fully trained and implementing them.

Failure to maintain adequate staffing


Staffing has been an ongoing challenge at CCDC. COCHS has identified several staffing concerns
impacting risk, contrary to reports that CorrectHealth is fully staffed. This week alone COCHS
observed that there was only one LPN on evening shift in the infirmary. On this same evening,
the infirmary had twenty-one inmates, the jail had six people on suicide watch, and an inmate
had a Peripherally Inserted Central Catheter (PICC) line in the infirmary. In another instance, we
observed staffing sheets that reflected there were two LPNs staffing R&D on an evening shift
without an RN. Furthermore, this week Health Services Administrator Nurse Jean Llovet was
pulled to cover an overnight shift in the infirmary due to inadequate staffing. Multiple contract
provisions speak to CorrectHealths duty to maintain adequate staffing in the facility. At this
time we have determined that they are failing to meet this requirement.

Failure to maintain a full-time medical director


Related to the staffing challenge described above is CorrectHealths failure to maintain a full-
time medical director. According to the contract terms, CorrectHealth has a duty to maintain
1.0 FTE medical director whose responsibilities are clinical in nature. During discussions with Dr.
Musso and observations in CCDC we have determined that, at most, the currently assigned
medical director Dr. Smith is committing sixty percent of his time to clinical duties. The other
forty percent are devoted to providing telemedicine to other facilities or corporate
administrative tasks. Dr. Musso alleges that he is providing the other forty percent of clinical
time; however, this information could not be verified.

Failure to build effective relationships with subcontractors to ensure patient safety


COCHS has had challenges with accessing data and information from CorrectHealth, delaying or
impeding our ability to thoroughly assess compliance with the contract and the quality of
services delivered. COCHS has recently requested information from CorrectHealth that was not
provided to us. Specifically, we requested copies of monthly reports that CorrectHealth submits
to the sheriffs staff. CorrectHealth staff reported that they were not comfortable giving us this
information. A noticeable shift in CorrectHealths staff willingness to work with us has been
experienced during our visit on February 6.

II. Penalties
In order to provide you with the most accurate determination of the amount Chatham County
is due, COCHS analyzed the data available. We have faced difficulties in receiving the
appropriate data and cooperation from QuickRx and CorrectHealth staff.

We used the following data sources to calculate the penalty:

1. Data on who provided intake screenings came directly from the electronic health record and
were provided to COCHS by Fusion, the licensor of the electronic record.

2. Data on the timing of distributions of pharmaceuticals came from the electronic data of
QuickRx. QuickRx refused to give that data directly to COCHS so we were dependent upon
CorrectHealth for that data source.

3. Data on vacant personnel positions came from the human resource records of
CorrectHealth. This information was forwarded to us from Dr. Carlo Musso. There were several
challenges with this data, not the least of which was that Mike DuBose, our Chief Executive
Officer, had an appointment with Jean Llovet, the Health Services Administrator, for Tuesday
morning, February 7, for data review, and Ms. Llovet proved unavailable to review the data
with Mr. DuBose.
Our professional opinion is that based on our data review, Chatham County is due $3,044,436
for the period November 1, 2016, to January 31, 2017.

The specific penalty violations include:


Medications: $2,126,2001
Intake screenings: $880,000
Staffing vacancies: $38,236

As we have also discussed, efforts have been made to assure that the County and Sheriff
Wilcher would be in agreement on how to proceed with the CorrectHealth contract after the
county commissioners have had the opportunity to review the amount of penalties due. At
approximately 12:30 p.m. on Monday, February 6, I asked the sheriff whether he would have
any issues if the county were to decide, based upon the penalty amount, that it was in its best
interest to terminate the contract with CorrectHealth. Sheriff Wilcher informed me that if the
County took such an action, then he may choose to keep CorrectHealth as the vendor for health
services in the jail by contracting directly with them.

One measure that the County could take in order to monitor the staffing compliance would be
to have the Policy and Accreditation Administrator at CCDC complete a daily staffing report. A
template to collect this information is attached. Per the Policy and Accreditation
Administrators title and job description, this is a responsibility that should already be a routine
part of this position. Please find this position description also attached.

Please do not hesitate to contact me with any questions you may have regarding this
information.

Sincerely,

Steven Rosenberg
President

Encl: Staffing Template and position description

1 Starting January 4, CorrectHealth began providing service interruption forms to COCHS that
serve as a justification for certain late med passes due to security issues. These forms are self-
reported by CorrectHealth and not signed by security. Given our experience with the log books
it might or might not be possible to employ the service interruption forms to validate security
as the causal agent of some of the late med passes. The data from these forms was not taken
into account in our analysis of late January med passes.