Report 2023-110 All Recommendation Responses

Report 2023-110: California Department of Public Health: Process Improvements Could Help Reduce Delays in Completing Fetal Death Registrations (Release Date: February 2024)

Recommendation for Legislative Action

To improve the average time it takes for fetal death registration statewide, the Legislature should amend state law to require hospitals, or any medical facilities where fetal deaths may occur, to initiate the creation of the fetal death certificate for any fetal deaths that occur at their facilities. In doing so, the Legislature should reaffirm that physicians, or hospital staff as their delegates, are responsible for entering the required medical information into the fetal death certificates and should clarify that physicians must sign the certificates before transferring responsibility for the next steps of certificate completion to funeral homes.

Recommendation for Legislative Action

To ensure the effective enforcement of fetal death registration timeliness requirements, the Legislature should amend state law to require CDPH to regularly notify the Medical Board, the Funeral Bureau, and any other relevant licensing entity, such as the Osteopathic Medical Board, of instances in which registration data indicate that physicians or funeral establishments are repeatedly failing to comply with these requirements. The notification should include the information necessary for the licensing entity to adequately investigate delinquent fetal death registrations.

Recommendation #3 To: Public Health, Department of

To reduce the time that parties involved in the fetal death registration process take to notify one another that a certificate is pending action, CDPH should, by June 2024, submit a request to its registration system vendor to develop and implement in the system an electronic notification mechanism that will alert the appropriate user outside the system, such as by email, that a certificate is awaiting that user's action.

6-Month Agency Response

CDPH Vital Records (VR) has fully implemented this recommendation. The new contract for the registration system has been signed and executed, and the vendor has planned to work on the notification mechanism in mid-2025 (see CHSI Response Support - Scope of Work - Contract Agreement.pdf). VR will be continuing and expanding on this recommendation further, by working with the vendor on the next stages to fully implement this change request.

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

60-Day Agency Response

CDPH Vital Records (VR) completed this recommendation and has already submitted a change request as part of the new scope of work for the registration system vendor to develop an electronic notification mechanism. (See Project Summary and Scope of Work.pdf) VR will be taking this recommendation further by working with staff and the vendor on the next stages to fully execute and implement this change request once the new contract is in place.

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

As part of the new scope of work for its registration system, CDPH has submitted a change request to the registration system vendor to develop an electronic notification mechanism. Although CDPH states the scope of work has been vetted and approved by CDPH internal leadership and the registration system vendor, the scope of work is still under review by the California Department of Technology. As such, we conclude this recommendation is partially implemented. Once the updated scope of work is finalized, we will again assess the status of the recommendation.

Recommendation #4 To: Public Health, Department of

To better fulfill its duty to oversee the fetal death registration process, CDPH should, by June 2024, begin to hold meetings regularly with local registrars to identify and resolve issues related to fetal death registration. CDPH should include in such meetings representatives for parties involved in the registration process—such as hospitals, physicians, and funeral homes—as well as representatives from relevant licensing entities—such as the Medical Board and the Funeral Bureau—to obtain additional perspectives about ongoing causes for delays.

6-Month Agency Response

VR has fully implemented this recommendation. VR held the first Death/Fetal Death Registration workshop - a forum specific to discussing death and fetal death related registration issues. Representatives from all areas of the death/fetal death registration process were invited to attend, including local registrars, medical facilities, funeral homes, and licensing entities. Attendees were invited to provide feedback and suggestions for future meetings via a survey. Staff are currently reviewing the survey responses from this workshop. VR will send out the survey bi-annually and hold Technical Assistance meetings to resolve issues that are identified in the survey. VR intends to use the survey responses to identify topics for and frequency of future meetings and incorporate stakeholder feedback to improve compliance with fetal death registration processes. (see CHSI Response Support - Death_Fetal Death Registration Workshop Invite Email.pdf, CHSI Response Support - Death-Fetal Death Workshop - Attendee Report.xlsx, and CHSI Response Support - DFD Registration Workshop Agenda - 6.27.24.docx).

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

60-Day Agency Response

CDPH Vital Records (VR) currently holds quarterly meetings (Quarterly Local Jurisdiction Meeting) where stakeholders are invited to ask questions and discuss vital records topics, including the fetal death registration process. VR is planning on scheduling regular meetings specific to the fetal death registration process, for a narrower group of stakeholders (e.g., fetal death registration system users, representatives of Medical Board, Cemetery and Funeral Bureau) to discuss issues at a more granular level. VR intends to gather input from stakeholders to determine discussion topics and establish agendas for each meeting. VR will consider the topics submitted and provide guidance during the meeting. Stakeholders will have the opportunity to ask questions and request clarification on the topics discussed.

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

Recommendation #5 To: Public Health, Department of

To better ensure the effectiveness of its help desk, CDPH should, beginning in June 2024, periodically survey local registrars to solicit feedback on their experience with the help desk and should use this feedback to improve help desk processes as necessary.

6-Month Agency Response

VR has fully implemented this recommendation. VR created a survey for local registrars to provide feedback on their help desk experience, which was sent out on May 28, 2024. The help desk email signature block now includes the survey link, allowing all users who interact with the helpdesk to access it and provide feedback. Survey results will be reviewed regularly and used to inform decisions around system enhancements, customer service, and fetal death registration process improvements (see CHSI Response Support - Survey Email.pdf and CHSI Response Support - EDRS FDRM Helpdesk Feedback Survey.xlsx).

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

60-Day Agency Response

CDPH Vital Records will create a survey for local registrar staff to provide feedback and suggestions, aiming to enhance the effectiveness of help desk support and improve the user experience for all registration system users. The survey will be created and sent to local registrar staff no later than June 2024.

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

Recommendation #6 To: Public Health, Department of

To mitigate registration delays and ensure that all hospitals and funeral homes with a responsibility to complete their portions of fetal death certificates are able to rapidly fulfill their obligations, CDPH should, by June 2024, notify hospitals and funeral homes that lack access to its registration system for fetal deaths of their legal obligations in the fetal death registration process and provide instructions on how to access the data system used to fulfill those obligations.

6-Month Agency Response

VR has implemented this recommendation. VR identified a list of funeral home and medical facilities lacking access to the electronic fetal death registration system. VR sent physical letters out on May 25, 2024, to the identified organizations, notifying them of their statutory responsibilities regarding fetal death registration, and educating them on the availability and advantages of using electronic registration to meet those responsibilities. The letters also included instructions on how to gain access to the electronic registration system and training for their staff. VR plans to send letter out on an annual basis. (see CHSI Response Support - FDRM Audit - Funeral Homes.docx and CHSI Response Support - FDRM Audit - Medical Facilities.docx).

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

60-Day Agency Response

CDPH Vital Records (VR) staff plan to reconcile the user lists of the electronic fetal death registration system, funeral home, and medical facilities with the lists of licensed facilities in California. This process aims to identify organizations not currently using the electronic system for fetal death registration and encourage their participation. VR will notify the identified organization of their statutory responsibilities regarding fetal death registration, and the availability and advantages of electronic registration to meet those responsibilities, including instructions on how to gain access to the electronic registration system and provide training for their staff.

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

All Recommendations in 2023-110

Agency responses received are posted verbatim.