Clinical Preventive Services
During our recent on-site survey, the surveyors cited noncompliance with standard B-03 Clinical Preventive Services. This is confusing to us since our policy and procedures for B-03 state that we follow nationally recognized standards. Can you provide clarity on how we need to address this?
Often the compliance issue with this standard has to do with an inconsistency between written policy and practice. Most facilities have policies and procedures in place, but the actual practice does not always reflect the policy or the national guidelines the policy is based on.
For this standard, these inconsistencies are usually discovered during chart reviews. Upon review of the medical records, the physician surveyors may note that actual practice is not in compliance with the written policies. For instance, they may find that screenings being ordered do not follow the facility’s policy and/or national guidelines.
While it is important to have clear policies and procedures, it is equally important to conduct periodic chart audits to ensure you are doing what you say you will do for your patients. Trust what you are doing, but periodically verify with a chart audit.
— From CorrectCare Volume 35, Issue 1, Spring 2021
Our state performs hepatitis testing on admission into our prison system. We are finding that approximately 30% of our inmates are positive. Subsequently, our physicians have been ordering tests and treatment for these patients. Do the standards discuss hepatitis screening on admission?
In the 2018 standard P-B-03 Clinical Preventive Services, compliance indicator #4 requires that the responsible physician determine the medical necessity and/or timing of screening for communicable diseases, to include laboratory confirmation, treatment and follow-up as clinically indicated. Similar language appeared in previous editions of the standards under the requirements for initial health assessments. The responsible physician also makes the decision as to which diseases to test for on admission.
Also note that Standard F-06 Response to Sexual Abuse does require that prophylactic treatment and follow-up care for sexually transmitted infections or other communicable diseases (e.g., HIV, hepatitis B) be offered to all victims of sexual abuse as appropriate.
The 2018 standards mention hepatitis in a few other areas, as well. A-04 suggests that infectious disease monitoring (e.g., hepatitis, HIV, tuberculosis) be included in monthly statistical reporting; B-01 recommends that hepatitis A, B and C be included in educational programming; and E-05 recommends further questioning regarding history of hepatitis and other health problems as a follow-up to the mental health screening.
— From CorrectCare Volume 32, Issue 4, Fall 2018
In the 2018 Standards for Health Services for jails and prisons, B-03 Clinical Preventive Services was renamed. What was it called before?
In the 2018 manuals, a table listing changes between the 2014 and 2018 editions shows B-03 as “renamed.” Although the title of the standard is new, much of the content comes from the 2014 standards. Below is a list of the B-03 compliance indicators and a breakdown of where the content appeared in the 2014 manual and/or whether the content is new:
- CI #1 – new content
- CI #2 – from 2014, E-12 Continuity and Coordination of Care During Incarceration (CI #10)
- CI #3 – new content
- CI #4 – from 2014, E-04 Initial Health Assessment (CI #2e). Note that the responsible physician now determines the necessity and/or timing of this testing, rather than a blanket requirement or a letter from the health department regarding the prevalence rate not warranting testing.
- CI #5 – from 2014, B-01 Infection Prevention and Control Program (CI #2b) and E-04 Initial Health Assessment (CI #2f)
— From CorrectCare Volume 32, Issue 3, Summer 2018