Q&A: How Kaiser Permanente has handled change brought by COVID-19

Compliance Week recently caught up with Vanessa Benavides, senior vice president, chief compliance and privacy officer at Kaiser Permanente, to discuss how the company adjusted its policies and procedures because of COVID-19 and the lessons she learned along the way.

Q: Tell us a little bit about Kaiser Permanente.

A: Kaiser Permanente’s model of a nonprofit health plan and hospital system is recognized for the outcomes it achieves in pursuit of its mission: to provide high-quality, affordable healthcare services and to improve the health of our members and communities we serve. We also invest significantly in the geographies in which we operate by supporting community organizations and providing community and social health resources. We have 12.5 million members, 217,000 employees, and 88,000 clinicians, and we currently operate in eight states—California, Colorado, Georgia, Hawaii, Maryland, Oregon, Virginia, and Washington—and the District of Columbia.

A major differentiator from other health systems is Kaiser Permanente’s unique integrated system, where all patient care interactions are seamlessly integrated with Kaiser Permanente’s electronic health record to create a better patient experience and help assure greater quality and safety during and after the visit. Our integrated approach to providing physician-led health care and prepaid financing of coverage drives coordination of care across all settings and care teams. This enables quality outcomes by ensuring that our members receive the right care, at the right time, in the right setting, avoiding unnecessary costs by eliminating care complications and unnecessary or duplicate tests or procedures that occur when care is not coordinated.

Q: What are your roles and responsibilities as chief compliance and privacy officer at Kaiser?

A: My responsibility at Kaiser Permanente, and the role of the larger ethics and compliance department, is to ensure our ethics and compliance program is effective. Essentially, the purpose of our program is to build and protect trust in our organization. Trust is essential and needs to be built and maintained with our members, patients, prospective members, communities, regulators, employer groups, and others so they will choose to have a relationship with Kaiser Permanente in whatever capacity that might be.

Q: How has Kaiser had to adjust its policies and procedures amid COVID-19 to keep employees both safe and compliant?

A: While ethics and compliance are always organizational priorities, the pandemic highlighted certain perennial imperatives that are especially critical. COVID-19 increased certain compliance risks, which prompted us to look at our current policies and procedures and adjust, where necessary. For example, with most administrative personnel working from home since March 2020, there is increased risk around the privacy and security of sensitive information and the proper retention and disposal of business records. We issued extensive guidance and protocols for remote workers to limit technology risks while working from home.

The pandemic brought new vulnerabilities that increased criminal activity, such as supply chain scams, external claims fraud, and cyber-related fraud (e.g., phishing). We relied on the solid processes we had in place to address these risks and enhanced those processes to include vulnerabilities specific to the pandemic. These enhanced vulnerabilities were included in our compliance risk assessment process and have been fully incorporated into our ongoing workflows.

Kaiser Permanente has also taken many steps to manage and maintain an ethical organizational culture throughout the pandemic. This includes ongoing communications to our employees about navigating this remote, virtual environment ethically and compliantly. The compliance team elevated our presence on internal communications platforms by sharing highlights from our code of conduct and reminding our workforce how to report ethical concerns.

Additionally, we issued guidance on accepting and acknowledging expressions of gratitude, as offers of donations increased during the pandemic. We also launched an employee survey that captured perceptions of how Kaiser Permanente is supporting its employees during the pandemic and provided areas where they could comment under each question, which we looked at qualitatively. We evaluated this survey information and used it to help us look at areas where we could improve.

Q: Maintaining the health and mental well-being of employees is a unique struggle all organizations face right now. How is Kaiser tackling the challenge?

A: Over the past 17 months, we provided $375 million in employee assistance to ensure frontline employees had access to alternate housing options, special childcare grants, and two full weeks of additional paid leave for COVID-19 illness and exposure. In addition, our represented employees have received step wage increases and guaranteed annual wage increases.

Early in the pandemic, Kaiser Permanente implemented a 24/7 help line (Here4You) to connect employees with childcare providers, mental health programs, and other health and wellness resources. During the nearly 10 weeks these temporary benefits were first in place, more than 50,000 employees took advantage. Kaiser Permanente has also increased its promotion of our Employee Assistance Program to help our employees care for their mental health. We gave all of our employees free access to the Calm app (for mental health), have added access to online fitness programs through KP Fit, and added more seminars around meditation and well-being.

In addition to our COVID-19 offerings, we have increased seminars around equity, inclusion, and diversity that are sponsored by our various employee resource groups. For the first time in 45 years, we hosted our National Equity Inclusion and Diversity Conference completely virtually, allowing all employees the opportunity to attend.

Q: How has COVID-19 changed Kaiser’s approach to ethics and compliance training?

A: Kaiser Permanente hosts an employee-required annual ethics and compliance training, which typically launches the first week of May. With the added workload to our employees in 2020 due to the pandemic, we decided to make changes to our rollout and delivery strategy to give our employees a more flexible deadline to complete the training. This allowed our employees an option to take their training early while working from home, and our frontline healthcare workers had more time to complete the training requirements around their regular duties and new stresses.

Q: What unique challenges has COVID-19 created concerning the supply chain, and how is Kaiser tackling those challenges?

A: The COVID-19 pandemic has revealed to the healthcare industry the fragility of medical product supply chains, especially in the categories of personal protective equipment (PPE) and critical medical products used to care for our members and patients. In the wake of COVID-19, Kaiser Permanente enhanced its focus on third-party risk and carefully assessing and developing contingencies for its supply chain.

Internally, Kaiser Permanente streamlined some of its sourcing processes to meet the increased demand for PPE. We balanced this by increasing controls and monitoring of suppliers, alongside re-emphasizing with vendors the importance of adhering to our vendor code of conduct and the consequences for noncompliance.

Externally, Kaiser Permanente performed outreach to our most vulnerable suppliers, particularly those in communities of color, to connect them with resources to support their continued viability and resilience during these challenging times. The pandemic also reinforced the importance of Kaiser Permanente’s spending efforts with local, diverse suppliers and has driven our organization to invest further within our communities. In 2020, we spent $2.56 billion with diverse suppliers, an increase of 27 percent over our 2019 diverse spending. We also spurred $510 million in diverse spending by suppliers on our behalf in 2020.

Q: As a chief compliance and privacy officer in the healthcare sector amid a pandemic, what broader lessons have you learned over the last 16 months?

A: I think we’ve all learned the value of being flexible and adaptable when facing challenges beyond our control. That’s certainly true for compliance programs and compliance professionals. Being able to quickly adjust to new work locations, processes, and priorities is essential during the pandemic, and I believe it will continue to be so going forward, even post-COVID-19.

The past year and a half also reinforced the importance of communication, particularly during a crisis. We’ve had to communicate more frequently and using different channels. Those informal, “watercooler” conversations aren’t happening nearly as often due to more people working remotely and those working on the frontlines being necessarily focused on patient care. So, we’ve had to be very intentional about reaching people where they are.