Webinar: Masterclass – How to Cut Days from Your Issue Open Rate

Transcript for How to Cut Days from Your Issue Open Rate

Giovanni Gallo: Hi, everybody. I’m so glad you could join us. Thanks for your patience as we got launched here. We’re super excited today to host and to welcome you to our Masterclass, How to Cut Days From Your Issue Open Rate. We’ll be hosted by Matt Kelly, and have panelists of Lisa Fine and Jen Bibb. We’re so glad that you’re sharing some of your day with us. And we really hope that this is something that makes you better, makes you more successful, and enables you to serve your team and your mission better. Nick, you wanna take us to the next one?

Nick Gallo: Yeah, thanks, G.. So, please send in your questions, send in your comments so that we can incorporate those and turn this, you know, into more of a conversation. We’re super excited about this topic. I think it’s top-of-mind for a lot of us and I think there’s really great takeaways that we’re gonna to have here. So, please stay tuned, and please participate. A little housekeeping we will be sending around the replay for those of you who want it. You can share it with other folks on your team will have also an asset to send around as well. And finally, those who are interested in SHRM credits, we’ll have someone pass those on as soon as those are ready. So, if you have any questions reach out anytime. Other than that, Matt, you can take it from here and everybody enjoy.

Matt Kelly: Sure. Thank you very much, Nick. So, hello, everybody who’s listening. We have two guests with us today to talk about hotline operations, and how you can integrate your hotline into your greater compliance program, what it means for good corporate culture, how to overcome some of the common obstacles that people have with compliance hotlines. We’re gonna cover a lot of that ground. So, first with us is Lisa Fine. Lisa is Director of Compliance for the Americas for Pearson. Lisa, hello. Thank you for joining us.

Lisa Fine: Hi. Thank you.

Matt: Also joining us is Jennifer Bibb, who is a compliance consultant with Sentara Healthcare. And Jennifer, I know you are online, but we had some technical difficulties with the camera, but you are out there, I believe so welcome. Thank you.

Jennifer Bibb: Thank you.

Matt: I guess I wanted to start very generally with just asking about your views on the hotline’s place in your whole corporate ecosystem, what you wanna do with it as a tool. So, that would be maybe my first question. Lisa, I’ll start with you and then Jen, you could give us your thoughts. But in that ideal world, aside from all the problems of getting a hotline up and running, and we’ll get to the problems and the obstacles soon enough but what is your vision for the role that the hotline would play in the compliances program? What’s the dream status?

Lisa: Well, the dream status which, is nowhere close to reality in a true utopia, is the idea that everybody feels so comfortable escalating any issue to their managers, to the company that you wouldn’t actually need a hotline or a helpline. Now, I’m gonna go back into reality because when you say, “What is the ideal,” the ideal is the workplace that, you know, is so open that that’s not an issue. Now, with that said, that’s never gonna happen and if it does at someone’s company, please let me know how you did that because I could use all the help on that. But with that said, you know, I think that the vision of it is, it’s still almost an insurance policy. That you always know that you have this option that people feel if they can’t reach out in any other way, that it’s there. That everyone is aware of it, that people are aware that it is effective, that they can get, you know, answers, results, and follow-up, maybe not always the result that somebody wants when they raise an issue, but to feel that they’ve been heard and concerns have been addressed and doing it in a way that is very catered to how your organization works.

So that if you have an organization and the people that are very attacking in these remote days always on their computers, how does it work that’s most effective for them. So, in the ideal world, it is something that is well-publicized, that people are comfortable reaching out to, that is results-oriented, and, you know, that is also tailored to the type of population or populations you have.

Matt: And, Jennifer, what’s your take on the same question?

Jennifer: Yeah, I agree with what Lisa said with everything that she said. You know, you wanna make sure that employees are not… You know, I think the biggest issue that you have with employees not speaking up is that fear of retaliation, and also the, you know, is someone really going to listen to what I have to say? Are they really gonna take action and look into my concerns? And again, if they don’t feel comfortable going to their, you know, direct reports, then that speaks volumes in itself. But you also wanna make sure that they’re kept confidential and they have that avenue to report their concerns. It’s just, you know, we have a number of ways that we have for our employees to reach out to us. And the hotline has always been the go-to, I think, for most employees to reach out about their issues.

Matt: Yeah. And Okay, so now, let me continue pivoting back in the real world. That’s the ideal of how the compliance hotline works. But what are some of the practical problems that either you see the most often or that you think are most difficult to overcome? Whether that is getting the sort of the cultural buy-in that using the hotline is okay, is it the technical stuff of figuring out how do I make all these phone numbers around the world or in these many languages? How do I make that work? What are the sort of challenges that you think are most significant? And, again, I’ll start with Lisa and then Jennifer.

Lisa: Okay, I mean, I think that there are a lot of obstacles that everyone’s aware of. The telephone lines can always be a challenge throughout the world. If we talk about technical challenges you have that. You have the app versus the phone. I think, you know, we can talk about those in more detail a little bit later and where the phone falls into things. But with that said, I also think the obstacles, I think there’s a huge cultural obstacle because for example, you know, if you’re in a U.S.-based or U.S.-focused organization, the way a hotline or helpline is perceived by employers or others in different countries, in particularly the EU, or, you know, in Asia and how it’s used, you have to kind of be very sensitive to that and make sure that people understand what it is to be used for, and you have to address it differently in different areas. So, I think there are a lot of cultural challenges to it. I think there’s also sometimes a lack of trust in who’s investigating because there are situations where individuals do not want HR to be investigating whatever they’ve already discussed with HR and it may be an HR issue versus a compliance issue.

You know, there’s a lot of challenges with investigations as a whole, and how to make sure that they’re being done properly. I think those are two or three that come up for me off the top of my head, technical, you know, cultural, and actually effectively addressing and, you know, going through investigations. And I think, you know, coming up with a true speak-up culture is really the big challenge in a lot of this because if somebody is not happy with the resolution of their case, they may just…you know, even if it may be the right resolution, they may then just say, “No one ever listens.” So, you’re fighting that as well.

Matt: Jennifer, what do you think?

Jennifer: Yeah, I see the calls and hear their complaints that no one ever listens. We’ve already talked to management. We’ve already talked with HR and so sometimes they look at that as the compliance line you’re calling, the hotline, as the last resort for them to reach out. So, yeah, the trust in the line and the investigation to make sure that their issues are gonna be heard. And also language. We do have…one of our facilities is in an area that has a lot of different nationalities. It’s like a melting pot. And so, it’s important to be able to have that, the use of a language line to assist those callers so that they are able to make their concerns be heard and not fearful because they don’t have as much of a grasp on the English language to make the call. So, those are some that we run into.

Matt: You know, Jennifer, tell me a little more about how important the actual hotline or the phone is to your whole internal program because I know there are executives out there who will ask, “Do we actually need a phone technically under the law? “You could say, “No, you don’t need a phone. The Sarbanes Oxley and the SCC, they don’t say thou must have a phone.” But how important is that to you? And Lisa, I’ll ask you the same question afterwards, that we just still have the same old method of communication we’ve always had?

Jennifer: I think it’s extremely important to still have the phone. You know, like, I know when I call customer service, if I have an issue, I wanna talk to somebody and make sure that I actually did get a person not just sending an email, or complete a form that supposedly goes somewhere and you hope you get a response on it. I think, you know, if you get that empathy from talking to a live person, even if, you know, it’s just their job to say, “Oh, I completely understand,” or whatever the response is, you feel heard. So, you already feel like step one is being checked. You know, you were able to make sure your concern is known. And you spoke to a person, not a voicemail or not through an electronic means. So, I think it’s huge to have the phone still.

Matt: Okay, Lisa, what do you think?

Lisa: I’m gonna give my first lawyer answer of the day with a little bit of an, it depends, and here’s why. Again, I’m just gonna talk about my experience in two organizations. One where you have a lot of people in an operation that do not sit around computers or are more comfortable with that all day in a population of people who really want to speak and want to be heard, just like, as Jennifer said. And I think it’s always important to have that. I do think, and I will say, I also think it’s more important now during COVID because I think people are feeling more alone. So, hearing a voice is really important. On the other hand, I am a proud GenXer, but some of the millennials are even Gen Z now. They want the app. They want the phone. They don’t relate as much to that or people who are so tech-focused. So, if you’re an entirely tech-focused company, where you’re doing everything through chats or WhatsApp or, you know, other things, I’m just not sure that it’s as important but I do think it’s a very important default.

So, what I’m saying is over time, in some circumstances it may be less important. But I do believe generally exactly what Jennifer said is that you do ultimately wanna know you can reach somebody. And I think if you think about it, as I mentioned earlier, as an insurance policy for what it’s gonna cost you as a company or an organization to have the comfort that you have that tool is well worth it for the person who isn’t gonna feel comfortable any other way, I think when you think about comfort levels. But the answer to that might change in 5 or 10 years. I think it’s important to focus on the, yeah, sorry, on the online components as much or more but also to make sure you’ve got phones working as a tool.

Matt: Yeah, Jennifer, could you just tell us a little more about your various intake methods? I don’t know but I’m assuming you do allow web submissions or something. But what else in addition to the phone?

Jennifer: You know, we’ve got a direct phone number to our department as well as to our staff we have a direct number to our compliance department. And then we also have an email address and that’s posted on our company website. And then on both our intranet and on the company website, we have a form that they can complete. And the one on the website is they can choose to be anonymous or not. So, for those people who want to go ahead and complete something that way, they can do that. I do find our line and I think we’re gonna talk more about this later. But our line is open to employees and patients and their families. So, we have a lot of elderly people calling and, you know, we know they’re not as tech-savvy and may not even have a smartphone or, you know, to get online and do these things. So, for our base of our calls, you know, it’s important for us to be able to have a phone number for them to be able to access us.

Matt: You know, in a few minutes, I do want to get to how you encourage people to use the hotline, how you tell them that it exists, and who else aside from employees might participate. But before we get to that, I also did just wanna pick up one more point about intake, the very popular belief out there that a lot of complaints, issues, intake, actually, is employees speaking to managers. And how would you each try to capture that dialogue and make sure managers know, “Oh, I’m getting a complaint. I should tell somebody or I should fill out this form and pass it off,” and they input the system? How do you make sure that you capture that sort of activity? Lisa, I’ll ask you first.

Lisa: Well, I think it’s a challenge because I think sometimes with managers they may not necessarily consider an issue that should be escalated as one that’s outside the day to day, you know, dealing with personalities within the business. So, it is a challenge. I think, one of the… I think there’s a combination of things. Within any trainings that you’re doing, not just from a compliance standpoint, but from an HR or general business standpoint is if certain concerns are raised, you should or you must, you know, get in touch with an investigation team, or a manager. I find that word a little bit more intimidating, but, you know, a compliance team or part of the function. I think as a function, it’s our responsibility to make it more welcoming to do that so people don’t feel like, “If I go do this, I’m going to get in trouble.” So, I think there’s a lot of training that can be done about that.

And I also think informal discussions with people that are in the business who may be more likely to hear more issues and reports. And it is a very helpful approach because while you can’t talk to everybody, you can basically have people say, “This group is going to help us with the problem and also hold people accountable when something goes wrong.” And I guess the last part of that is to let managers know. Take it out of your hands, you know. Let us deal with it. You did your job.

Matt: Do you guys go as far as to flag some specific issues for managers in their training? Like, if somebody tells you they think it’s accounting fraud, please tell me. Don’t handle this on your own. I mean, is it that specific that there are hot button issues?

Lisa: Yeah, I mean, if there’s something like if you think somebody’s, you know, fraudulent expense report, or accounting issues, or, I mean, in that’s from a true compliance standpoint. And on the other hand, if you also hear something that sounds like retaliation, or discrimination, or concerns like that, or people treating each other poorly, we want those to be raised as well so that they can be, you know, recognized and accounted for and to acknowledge what these concerns are. So, yeah, you can give those kinds of examples.

Matt: Jennifer, how do you try to accommodate all of that activity and what do you do to train managers and what are the issues that thou shalt must bring this to my attention, that kind of stuff? How do you handle that?

Jennifer: Yeah, we do have it in our training, in new hire training and our annual training, and then we also have new leadership training for new managers. And we go through some of those scenarios. Privacy sits in there as well and does some examples. But we try to give them you know, like, “Hey, if you see this, bring us in so we can help you with it and we can investigate it for you and look into it further.” We work very closely with HR. So when complaints are raised to them if it hasn’t come through our hotline, they know to reach out to us for compliance issues so we can get involved in the investigation as well, or if it’s privacy, the same thing. So, it’s more, you know, we do try to encourage everybody to report it and, you know, to reach out to compliance. Even if they just get HR first, HR knows to bring us into it. It’s a lot of education around that.

Matt: Could you talk to us just a little more about how to have friendly and productive relations with the HR department? Because I know that’s a perennial issue of discussion among compliance officers. Jennifer, how do you do that? Then, Lisa, I’ll ask for your thoughts too.

Jennifer: Yeah, we have a great relationship with our HR department. A lot of our calls that come through the hotline tend to be HR-related. So, we work well with them to make sure that they’re getting them and that they’re closing them out. And we’ve done audits with them to make sure that the calls we’re giving them do not have any compliance issues because we don’t necessarily get their full report on it. They keep that in their own system. But just that, you know, making sure that they know that we’re here to help them as well, you know. We have had, you know, especially when there are senior leadership individuals that are involved in calls that we need to keep this more confidential, you know, we work with them on that. And I think that, you know, helped establish a good level of trust between the two departments to know that we are there to help each other and we do wanna keep everything safe…everyone’s safe and conduct investigations as thoroughly as we can.

Matt: Sure. And Lisa, how does the compliance HR relationship work from your perspective?

Lisa: I think it works. I think it really requires a lot of sort of trust and getting to know each other. I think there is always a concern of scope creep either way, like from an HR side. Why is compliance you know, getting involved in this? We’ve been dealing with these particular issues for a while. But I think keeping an open line and keeping, you know, picking what are your key most important battles in mind as well if you are having some of those tensions because those are gonna be addressed. I also worked in HR compliance before I did this and did an HR side of investigations. So, there’s also a part that I think people forget from the HR side is that everybody is always, you know, somewhat irritated with HR about something, whether it’s the benefits, whether it’s something… You know, there are a thousand things unrelated to this. So, oftentimes, they’re really trying to do their best in a fairly thankless role as well.

So, you know, to basically remember that and acknowledge it, you know, on some of these things, because they’re dealing with people’s problems every day because I don’t know, I see there about a hundred people on here. I wonder how many… You know, it’s not like, we often go to HR and say, “Thank you so much for doing an excellent job on, you know, in the U.S. Open Enrollment. You know, I waited four hours for the call.” And that’s separate from the investigation side, but if people lump that together to acknowledge that frustration and to be a team with them, I think is tremendously helpful. And not an I versus them. It’s not us versus them. We’re all trying to make sure we do the right thing.

Lisa: I think that doing our audit that we did that definitely helped, you know, bridge that team between the two of us. So, it wasn’t us against them. You know, HR does their thing and compliance is there is it really helped the people who are working the calls understand the entire process, which I think as part of it as well. They might just be getting the report and saying, “Okay, we do our job.” They don’t really see the whole picture sometimes. And I think by doing the audit of the calls we sent to them that that really helped bridge that relationship.

Matt: Okay. Jennifer, tell us a little bit more about how you do preach the gospel of the hotline and its availability because you mentioned that it’s not just for employees, but it can go out to patients, their families, maybe other third parties. So, I am curious about how wide open the hotline is, and how you just tactically, how do you get that message out? Especially for people who aren’t hanging out in the break room and they see the poster and the phone number how do you reach all the third parties and whatnot? What can you tell us?

Jennifer: So, we do have it on our website. And we also have it on our patient, the release of information form. And, you know, there’s lots of numbers out there and everybody sees them. I think sometimes people just see any number and start calling to try to get a person. But we have it on in various different materials that are given to the patients. And a lot of times we’ll have patients call and they’ll say, “You know, a staff member or the nurse told me to call you,” or, you know, tell us that someone else told them to call, which is in my eyes, I think that is a positive because that means that our employees do know that we have the hotline and we do have an avenue for, you know, for the complaints and issues to come through that we might need to be involved in. But again, it’s mostly you know, patients are a lot of them, but we do have the employees, but the patient ones a lot of those are patient care concerns. And, you know, sometimes we need to get involved in that. There are some higher issues that are involved.

Matt: And so, Lisa, Pearson is a big global player in education materials and publishing along those lines and testing and whatnot. So, how does that work with you and your populations? Like, does Pearson take calls from third parties on the hotline? Do you encourage it or how does it work?

Lisa: We don’t discourage it, but that’s not our main focus on it. If somebody has a concern, we’ll raise it, but a lot of times if somebody has, you know, a concern about a textbook or issues like that, you know, we’ll see that as a referral and refer that out to somebody within that part of the business because we can’t… You know, if somebody tells you they had trouble getting a standardized test location it’s very different than a cheating allegation, or, you know, inappropriate behavior by a test monitor or something like that. But we do have in test centers, you know, poster information for the in-person side of it. But our major focus for it is for our employees and also, you know, sometimes it’s for people who may be in negotiating agreements or actual, you know, supply chain or third parties. But that’s not our main focus.

We really focus more on our internal population, but we do keep it out there as an option for others because like Jennifer said, sometimes they just want a number to call or be able to go… Our website is called pearsonethics.com. We talk about that a lot just to know that, you know, if people will do that, and we respond. So, that’s where we fall on it. But, again, we’re not dealing with the same kind of life and death patient care issues, although I think education is very important. So, it’s a little different in some of the urgency levels.

Matt: Yep. I wanted to shift gears bit and talk a little bit more about the mechanics of how hotline programs work. And one big focus, I think, would be how you do manage the intake of complaints. So, you know, if you are a compliance officer trying to, I guess, standardize the information you wanna get from complaints that are coming, and they’re coming maybe from multiple channels, web submissions, or hotlines, or a manager reports something to you, talk to me about the points of data, the information you’re trying to extract, and how do you put that into a discipline to intake process? Lisa, let me ask you first, and then Jennifer. But, you know, what’s the…how do you map out what you want to get out of an intake process?

Lisa: I do wanna circle back quickly to one point, Matt, that I just wanna make sure about the publicizing it because this is something that I find is important, that it shouldn’t only come from ethics and compliance professionals. One of the things that I try to do that’s very, you know, low-dollar value but makes a huge difference to employees is to ask people throughout the organization, whether they’re a leader or a manager to say at some point, “If you have a concern, I hope you feel comfortable raising it to me, but if you don’t you, even if it’s with me, you should go to pearsonethic.com, go to a hotline,” because I feel like I just don’t want that point to get lost that we can do so much in our roles. But if somebody’s manager says, “We wanna know what’s going wrong, so much that I’m going to tell you to reach out,” I think that that is kind of the best publicity, you know, you can get. So, I just, you know, I wanted to when we talk about promotion, we talked about all these traditional things. I think it’s, you know, if you can get managers to say that, that helps a lot to sort of build the community.

Now, I’ll go back to your point because I really just didn’t wanna miss that one because it’s one that’s important to me. You were talking about, you know, how to standardize the intake of reports. And I think that you need to get the basics. I also think that, again, coming back to culture, a lot of things, you wanna get enough details to cover what’s important and give the individual the opportunity to say whatever they want to say. But you also don’t wanna make it such an arduous process that halfway through, especially the intake form online or on the phone, if somebody says, “Okay, can you spell that person’s name again, I missed this,” or the technology works to frustrate people.”

So, I think in some ways, you wanna make sure you’re getting the information, you know, the basics, who, what, when, where, why, you know, in the easiest way possible, and that free text of what actually happened and what are your concerns and why did you do, you know, how many times, stuff like that. So, I think from a practical standpoint, having a zillion questions, that will be great for your metrics down the line can sometimes be harder for the report.

Matt: Jennifer, what are your thoughts?

Jennifer: Yeah, I agree with Lisa, you know, and I was thinking about that as I was listening to her speak that, you know, I think, you know, having online forums is great. You know, we talked about the Gen Xers and everybody, you know, wanting to use more technology, but if you do have, like she said, too many questions and too many, you know, entries for them to complete in something, I think that people might give up. So, you wanna make it as simple as you can with still getting that valuable information so that you can complete an investigation. It’s hard to get that if you have too many questions for them, I think. I think you just get bogged down in it and like she said, you know, having that free text and the conversation of letting them just tell exactly what happened is important.

Matt: And tell me a little bit more about how you would, I guess, train live people, or how would you get all of this information from hotlines? I will put aside online forums because you’re right, you can have the pull-down menus and the buttons and the options and an open text field. But if you are looking for that same sort of extract the key points from people who are taking the call from another person who may or may not be distressed or might be speaking in a different language or something like that, how do you get that normalization from the hotline specifically in the call center reps and whatnot? Do you do leave it to…how much judgment do you leave with them? How much do you carefully script all of this? How does all of that work?

Jennifer: Well, and that’s one thing I’ve been thinking about lately is how we can get some more information. We’ve had a couple of calls come through in the past couple of months with, you know, that don’t have enough information, and we’re just kind of stuck, but we wanna investigate. But, you know, we have 12 hospitals and multiple different divisions and lines of business. Excuse me. And it’s kind of hard if someone just says, “I went to your hospital,” and we don’t know anything about it. You know, we don’t know which hospital or facility. So, I’ve been thinking about ways that we can, again, not bog down the caller with questions, but what questions can we ask to better get the information that will help us? And so they’re not yes or nos, but that they’re easier for them to speak about the incident.

Matt: And, Lisa, what are your thoughts about how to sort of normalize the collection of data, especially from the hotline where it’s, you have to trust that a person giving an oral report over the phone to another person writing it all down, like that works well. You know, what are your thoughts about how to make sure that works well?

Lisa: First of all, part of that is I hope that whatever the provider you’re using is doing and I would work with them to make sure that they’re… You know, I have to think about what the best questions are for my organization. But that’s still also situation to situation. I mean, somebody anywhere who deals with fraudulent, you know, travel and expense reports, you can answer those questions. But I think that that’s one of the really important parts at the beginning of when you’re using a provider, that they are able to ask the questions that you choose and do it in an effective way. And if you need a translator have that happen quickly. not to have to have somebody sit for 10 minutes, you know, because some countries don’t have a lot of reports so they don’t have a lot of translater individuals on calls. I think that…you know, I mean, in terms of how the questions are asked, I’m not sure it’s easy to get the people that are on the line that are, you know, certified to get the information to be, you know, to be as intuitive or other things as the investigator.

But I think part of that is actually our responsibility after that as investigators to do whatever else needs to be been necessary. So, I really do think that’s part of that is really the role of why you would want a third-party provider–a little bit of distance, but it also…their responsibility should it be that the people are more, you know, are trained in the way to respond to those sorts of calls.

Matt: Yeah, I suppose my thoughts are about if you’ve got hotline reports come, or if you have reports coming in online, they might be fairly easy to structure to get the key data points if you wanna see how many complaints about harassment have you received. But if you also then have to integrate how many reports did the managers hear about, how many reports came in over the hotline, and then how do we correlate all of these different types of reports, so I the compliance officer can see across it so I know I’ve got a total of this? It seems like it’s a challenge to be able to correlate all the different types of reports to make sure you’ve got the right sort of data to analyze. I don’t know if either of you have any thoughts about it. But I’ve often wondered, how do you make sure that a report from a web submission, a report from a hotline, a report to a manager that, you know, they capture all the same relevant data, in the same way, to pass it up the food chain? It seems like it’s a hard thing to do.

Lisa: Jennifer, you wanna take this one first?

Jennifer: Yeah. I’m thinking about that. Yeah, it’s very difficult to get the same information, and a lot of times we’ll find that people have contacted someone else and another person at the same time. And which is great that we can all then get together on it and work together for those. But we do…you know, we track, you know, where the calls are coming from through the different avenues that we have. But they definitely do not all have the same information just because of the way that the intake is done. So, we have not…I wouldn’t say we have a firm grasp on that yet. And our form is fairly new that we’re using so we’re figuring that out, but it’s definitely a challenge.

Matt: Okay, Lisa, how will you try to approach that challenge?

Lisa: Well, first, I define them in a couple of different categories to start because for both phone hotline or helpline reports and the web submission, they have similar data points. And you really can at least look at that group and be able to compare who’s coming in through your speak hotline in a fairly consistent manner. I think the challenge is when a manager initially gets a report and what kind of report is it? Where does it…you know, is it even actually something that’s supposed to be an investigation? But I think once it gets through, I mean, you know, if somebody reports in through many different places that they did not like, you know, their shift being changed and they’re a union employee, they may think they’re being discriminated against, but it’s their seniority for example. And you can get it through several different avenues. So, you don’t necessarily wanna add that or have that in a metrics. That may truly be a business issue after you do the, you know, prime official review of it.

But the challenge is when something is, in fact, an investigation of that sort, and I really believe that the managers should then be escalating it to people who are more trained in their areas, whether it’s an HR person or a local compliance officer or a member of the legal team that’s regional to help start giving the guidance. And once you have the people that are trained to do that, or trained to escalate when they need to, you can get more of that data to make it more consistent. But I do think on some level, just because the method is so different of intake, it is somewhat complicated to make them both a consistent analytic thing.

Matt: All right. Just for everybody listening, I wanted to say that I probably… I have a few more questions that I’m happy to keep on posing. But if you do have any questions you want me to pose to Lisa and Jen, please pop them into the Q&A feature and we’ll get those up on screen and I’ll pose them. We’re gonna try and set aside about the last 10 minutes or so of the hour for questions. So, if you have any speak up, and let me know. I did wanna just pick up on what you were both saying about analytics. What are the hotline metrics that you would try to track regardless of how easy it might be or difficult that might be to find them all? Like, what are the actual metrics that you think are most informative? Lisa, I’ll start with you and then Jen.

Lisa: I mean, I think the type of issues that are being raised, geographically where they’re being raised, what part of the organization, whether it’s for example, you know, if it’s a basic sales-type issue or it’s in, you know, an enabling function, you know, have there been, you know, serious increases or decreases in particular areas? Also, looking at things that have been in the news because that, you know, like, you know, over the last few years from HR’s standpoint, Black Lives Matter, Me Too, others, have the things there, you know, resonated in some ways that you’re able to learn about some concerns that people may not have felt empowered to speak about in the past? So, I mean, I think geography type of allegation, you know, who’s making them and the numbers are some of the things that are the most important to me when you’re looking at it from a truly numbers-based standpoint.

Matt: Sure. And Jen, what are your favorite hotline metrics to look at?

Jennifer: Yeah, we track, so we break our metrics out when we present them to the board as, you know, calls that compliance handled whether we had to work with patient advocates or other individuals, the calls that we have, the calls that privacy manages, and the calls that human resource managers. And, you know, we track the average days close and average days open for those calls to make sure we’re staying on top of them. You know, we have a pretty good closure rate. Privacy has, you know, a lot of their stuff –we have a very small privacy department. So, it takes a lot longer for them to…it takes them longer to do their investigations since there’s only a few of them. But we do track that and we track the total for the other avenues. We just track those over all of the open and close. And then we also report, you know, the top five or six categories that we’re seeing of issues come through, you know, whether it’s a billing concern, if it’s, you know, HR with managers or privacy concerns, things like that, so we do track those as well.

Look at my dashboard. And we do that quarterly too. We report that quarterly to our boards and monthly we look at that with the compliance officer to see and see if there’s any trends coming through. Like with COVID, we saw in March an increase, of course, and outreach people trying to get in touch with someone. So, that was a big one but go ahead.

Matt: Well, I was going to ask, we do have a question from somebody here listening. Do you experience a difference in typical days to close based on different intake methods, whether it’s by web or phone or something like that? I don’t know if either of you have experienced that but any thoughts?

Lisa: Yes. It is a tough question and I’m taking a second because I think the days to close is really important. Obviously, a decrease of that as we’re speaking about it today, to some degree is important but also making sure it’s a thorough investigation. So, I do see that some things will take longer when they don’t come in through the helpline, or if there’s something that’s a longer-term issue. But I think those also depend more on sort of the level of urgency of the situation in terms of what the amount of time to close it is. So, I think that it doesn’t matter as much on the intake method in some ways, but I don’t have as good of metrics for the ones that are outside of the reporting mechanisms because it’s a little harder to get.

Matt: And Jennifer, have you noticed anything like that, that different types of complaints are faster or slower to close out?

Jennifer: You know, we don’t specifically look at each one of the other intakes except we just kind of lump all those together. But I do agree with Lisa. It depends upon the complaint or the call that’s come in or the email that’s come in as to the severity of it. Is it something that needs to be addressed, that’s urgent that’s gonna push your investigation or something else aside for a day or two? You know, that definitely plays a role in it. I think sometimes if we get something directly to us, I think a lot of people act quicker on that possibly. But I don’t really think there’s too much of a difference other than the severity of a call and the urgency of it.

Matt: Jennifer, you said something else that I’m glad you did and I wanted to pick up on it. How has COVID-19 changed your hotline experience? You said that you maybe you’ve gotten many more calls, I’ve heard that from others. I have heard others say that they now brief their board on hotline issues much more since COVID because that’s a great way to keep your finger on the pulse of the employee base in this very uncertain time. I was just wondering if you could talk a little bit more, Jennifer first then Lisa, what has it been like since COVID? You know, has the hotline become more important? Has it changed? Are you talking about these issues more often? What going on?

Jennifer: Like I said, we did have an uptick in March. March, April, and May were, you know, more calls for sure than the previous year. We are tracking, you know, month and year as well. And, you know, we saw more increase. I think people were just concerned and, you know, they were getting, they didn’t know who to go to for results. And again, like Lisa and I posted before, sometimes people just want a phone number to have a contact with somebody. So, whether it was directly to our compliance department or it was to our hotline, we were seeing more patients reaching out. And then employees were using the hotline more if they felt like they were being, you know, forced to work, having no option to not work a shift because they were concerned about COVID.

Matt: Lisa, it sounds like your audio has gone. Lisa, let me put the question to you. How has COVID changed your hotline experience?

Lisa: Oh, can you hear me though?

Matt: Yep. Go right ahead.

Lisa: Perfect. I think for ours, we had a little bit of a different experience because of the nature of the business we were in and we have a very remote workforce. So, a lot of people were…we had a decrease for the first couple of months because I think everybody was much more worried about their life and things that they might be calling about healthcare issues or that they were looking for, you know, phone numbers related to healthcare and they weren’t going to the office. What were the challenges and what’s happening now is now people have gotten more used to a new normal. And we had very few people go back into offices and almost no one that had to go who… You know, there was nobody who was being forced because we do have a remote base. But now there’s concern about job security, potential restructurings, other things that people will come out with chats or conversations that they won’t like behaviors and people aren’t in the same place to kind of talk right away.

So there might be skewing or miscommunication. So, we’ve had recently an increase on that. But that’s by nature of our business and I think that also we, unusually, actually have had an increase in people calling on our phones. Generally from people at Pearson are on their computer so much, they would use Pearson Ethics, but they do wanna hear a voice more. You know, and they will also reach out to the compliance office more than they did before.

Matt: Here’s a question from another listener. How can you encourage dialogue and conversation from reporters so that you can communicate that issues are being addressed? And I guess maybe I would first wonder how would you encourage a two-way conversation with a reporter who’s identified themselves? And then I’ll get back to anonymous reporting and how do you work with anonymous reporters if you can at all. But, Jen, your signal had konked out a bit a few minutes ago, I think if you’re back, I’d like to ask you that question. How do you encourage the two-way conversation with a reporter?

Jennifer: Right. Can you hear me?

Matt: I can. Go right ahead.

Jennifer: Yeah. You know, with our hotline, if they choose to be anonymous, of course, that has a little more challenge of having a conversation with them. But we can use a tool within compliance signs that, in the resolution where we’re able to pose questions back to them and, you know, give them our direct number if they wanna contact us that way. But we’ve used that a number of times to help keep the conversation going and get more information. And then if they are not anonymous, obviously, we can reach out to them and make sure that we have everything we need for the investigation, we’re not missing anything with it. The challenge, of course, with any way of reporting, whether it’s anonymous or not, is, you know, we’re not necessarily…we’re not gonna tell the reporter the results of the investigation and what was found. We let them know that it’s been completed. We can’t let them know if someone was terminated or written up or whatever for something.

But we can let them know that, you know, we have investigated their concerns. And if they have further questions, we direct them either to HR or whoever investigated it so that they can feel, you know, they have another avenue to reach out to somebody, you know. Again, it’s not that we’re gonna give them any results, but at least it lets them know that there is someone who worked on it. But we make sure all of our calls to the hotline have a resolution with some sort of statement about it.

Matt: Lisa, what do you do to encourage that two-way dialogue or build confidence in the system?

Lisa: It’s pretty similar. I mean, if somebody is anonymous, you know, we immediately sort of respond, either through the website, if it’s a web report and say, “This is a,…you know, I’m Lisa Fine. I’m the person investigating. You know, please let me know. Please reach out.” And then I often will ask a few questions that I would like follow up from. And sometimes they respond. If it’s anonymous, sometimes they don’t. And then eventually when it’s closed you do the same thing. If they don’t respond over time to your follow up questions and you’ve done your investigation, there’s only so much you can do but I do basically say, you know, “We completed the investigation.” Now, when someone is identified, it’s a little different because you can reach but a similar thing in terms of the initial reach out. But also in conversation, I ask the questions and I also do say at the beginning, as most of us do is, you know, “Here is what’s gonna happen, I want you to understand right now that at the end, we may not be able to tell you about what action has been taken, but that doesn’t mean it hasn’t been. And that’s because not only do I respect your privacy, we respect the privacy of witnesses and other individuals who may be helping on this.”

And even if people don’t love that part, the fact that they know is helpful. And I also tell them, you know, “When you do have an identified person if you feel you’re being retaliated at in any way, you know, reach out because…” And then I do also give an example. I’m like, “There’s retaliation but if for some reason after you make this report, you don’t show up to work for three weeks and you lose your job, that’s not retaliation,” and they usually laugh. But just to sort of understand, you know, that, you know, that just to say, you know, just to give a sort of a sense of, you know, expectations and also to kind of build a bridge and communicate with them.

Matt: Here’s maybe one last question to both of you along these lines, somebody asking, “Do you issue any sort of aggregate transparency report to employees where you might share some hotline metrics? If you do, what do you include in it? How detailed might it get?” I don’t know if either of you do, but that’s something that one person was wondering about.

Jennifer: I kind of touched on what we do for our metrics with that. You know, we don’t…they’re not…they’re published for our executive compliance committee and our audit compliance committee of the board. Those are the two groups that we share those metrics with. And then, you know, of course, if they want more information, you know, we revise them as needed, but that too. We really report our metrics too.

Matt: Okay. Lisa, does Pearson do anything like that? Any sort of public declaration of what’s going on with the hotline?

Lisa: You know, we really don’t and we do similar to what Jennifer does, although it’s an interesting topic that we’re talking about right now is can we do this better? Is there a way to talk about sort of some anonymized case studies? Is there a way to publicize things that will, you know, actually help in terms of the aggregate ones? But again, the number that come–like, so Matt, I’m sure like many people that are listening right now that you have the challenge of making sure everything’s actually reported in through whether it’s your management HR or others. So, it’s a great question and it’s something that we’re thinking through right now and trying to address, you know, best as well. So, for those of you who are listening, any suggestions or thoughts, you know, keep the dialogue going.

Matt: Well, somebody else did ask a similar sort of a question, whether it’s worth it to publish an anonymized or somewhat fictionalized account and in the employee newsletter? And then at the end, this came through the hotline. This is why it’s important. Please call. Somebody else was asking about that. I know we each…we have only about two or three minutes left. So, I just wanted to give each of you maybe a minute for some closing thoughts, maybe around, you know, the one best practice that you think is most advantageous for your hotline, the one thing that you either you think is most important that you do right or something you see other organizations do wrong that you’d recommend they fix. But Jennifer, what’s the one shot of parting advice that you would have? And then Lisa, I’ll ask you the same.

Jennifer: I think, you know, encouraging the speak-up attitude. One of our commitments is to have a questioning attitude. And so, we want to promote that and by, you know, having our hotline posters out there and having information in our trainings with examples and having it on our intranet I think is a huge step to make sure employees know that, you know, we do encourage them to speak up and that they are listened to. You know, that’s the primary thing is just making sure that, you know, you’re encouraging that speak-up and that employees know where to go to get that help.

Matt: Okay. And Lisa, what’s your parting shot of advice?

Lisa: I would, you know, go along with what Jennifer said. I also add to remember that, you know, all, everything that we do in our roles helps with the credibility and the comfort level for people to be speaking up and to be aware of the challenges from one place to another that are unique to your organization. Like phones are important in someplaces more in the country, stuff like that, to make sure you’re tailoring your speak-up to the way to encourage your organization to speak up. Don’t just look at some other place that looks like it’s fabulous for them and then think you can copy that. Really make it something that resonates with your organization.

Matt: All right. Well, Lisa Fine from Pearson and Jennifer Bibb from Sentara Healthcare, thank you very much both of you for joining me today. And Nick and Gio, I think you’re still out there. I’ll turn it over to you for any wrap-up comments if you have them.

Gio: Yeah, sure. You know, not much other than to remind everyone that we appreciate your engagement through this and asking questions. We’ll follow up with a recording of the video and your certificate and stuff like that within the next few days. And, you know, above all, I just wanna thank everyone who attended and shared some of your day with us to get some of these insights. Your commitment to be a better professional and a better ethics expert is making a difference in the world. And it’s gonna elevate all of our departments to this Compliance 3.0 environment where we’re a strategic lever to impact the entire business. So, I really appreciate your thought leadership. Matt, and Lisa, and Jen, you guys are great examples of thoughtful contributors, of people who really care about getting this done right. So, thanks everyone for being on today. And please get in touch with any of us if you have any questions or we can be helpful. Anything else, Nick?

Nick: Thank you all for attending. If you have extra questions, please send them on through email and we’ll get those answered and followed up on and I just appreciate everyone’s participation. And again, I appreciate Matt, Lisa, and Jen for spending part of your day with us.

Matt: All right,

Gio: Thank you all.

Lisa: Thank you.

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