CareFirst BlueCross BlueShield, the largest health insurance provider in the Mid-Atlantic region of the United States, is a member of the Business Ethics Leadership Alliance and a seven-time World’s Most Ethical Companies® honoree. CareFirst’s President and CEO, Brian D. Pieninck, is particularly engaged with matters of ethics and compliance—a trait not common among chief executives. While Brian was on his way to speak to a group of employees in West Virginia, Erica Salmon Byrne caught up with him for a long chat about his views on ethics and compliance, leading the company through a time of transition in the industry, and more.

Erica Salmon Byrne: Brian, why is it so important that you as the CEO are involved in ethics and compliance?

Brian Pieninck: From my perspective, this is as much about culture as anything else. People believe in where you spend your time and your energy, and from an organizational perspective, what you fund.

I think people seeing me engaged—not just superficially, not just when I’m pulled in by compliance or HR, but proactively as something that’s part of every conversation that we have—is important. And I think it puts a whole level of personalization on it, and people begin to think about it differently, in terms of the importance to culture and the importance to our environment and their personal accountability.

ESB: I know from the conversations that you and I have had that there are a lot of examples of how you very actively partner with Todd [Cioni, CareFirst’s Vice President and Chief Compliance, Ethics, and Privacy Officer] and the ethics and compliance team, giving not just company resources but your time, specifically. What’s your favorite thing that you two have done? What do you think has had the greatest impact, from a cultural perspective?

BP: From my perspective, hands down, it’s the opportunity to stand in front of associates and have conversations with them. It’s humanizing.

I think one of the things that a lot of organizations understand to some degree is that any time you’re dealing with risk, you’re striking a nerve with people. You’re plucking at strings that people are inherently uncomfortable with. And breaking down those barriers and humanizing topics like compliance and making them approachable to people, I think, is critical to getting honest conversations, honest observations, and progress. Any time we get a chance to just get in front of people and just have a real conversation, tell a real story, share a real anecdote, and create a safe space for this sort of discussion to happen organically, I think is the best investment that you can make.

ESB: How do you keep that message consistent while going through change? I know that your industry is going through a transformation now as a business, and that you’ve gone through transition when you moved into your role as CEO. Can you talk a little bit about how you think about values and using a values-based approach during that time of transition? Any examples you can give us of things that you feel have worked particularly well?

BP: These are the moments in your life, personally but also I think in organizations, when it can become a ripe environment for people to not do the right thing, for the wrong reasons. Even saying that out loud helps to draw focus and defuse tension. I think the most important thing is to share with people what you are not willing to compromise on, to help people understand what the guardrails are, and that even in the midst of change, even in the midst of urgency, even in the midst of growing complexity, even in the midst of growing volume, there are just certain things we are not willing to accept from ourselves individually or as the company collectively in order to forward other objectives.

And you’ve got to treat these things in principle as co-equal. These are equally important and they have to be done together. It’s not a choice of one or the other. I think acknowledging that up front gives people permission to think about it differently because otherwise, they might get caught up in mixed messages. For example, I’m feeling urgency around this business topic, and therefore I may feel implicitly that there’s a choice to be made here and that I’m being asked to make that choice, even if no one’s said it that way. I think you’ve got to talk about things like this—not that that’s a perfect antidote.

It’s important to help people understand that this is not an event. Transformation in business, based on business circumstances or societal circumstances, is no longer something that you do and then replant your feet for a prolonged period of time. Part of what we are trying to acculturate, and part of what we’re trying to control for, is this idea that we’re really not able to set our feet the way that we used to. The demands of our business require us to stay constantly in motion, so we need to get smarter about how we acculturate that motion, prioritize, and exercise sound judgment in real time.

I think that also helps people to recognize that if I’m waiting for it to get easier, quieter, simpler in order to make those difficult judgment calls, I should stop waiting and start prioritizing. I try to model behavior, and I encourage others to model behavior. When we see or hear something in conversations that begs a question, whether it be a cultural question, an ethical question, a compliance question, or a business operations question, we should use that as a teachable moment and say, “Let’s pause here for a moment on this particular topic, and let’s talk about the implications of what’s being said and what’s not being said.”

We try to do that pretty consistently, because I find that it provides real life context for people to learn from, that it takes discussion from conceptual to practical and helps people then apply it to their own work. Those are the sorts of things that we try to employ to make it manageable.

ESB: I call that sort of analysis “making decisions out loud.” Do you have a sense or have you talked to the members of your team about how they push that down inside their own organization? One of the things that we often find companies struggling with is, okay, the leadership team does this well, but how do I model that?

BP: I think this is the challenge, right? And I would not consider us to be unique, other than that I think we are building a culture where we’re persistently willing to say out loud to each other, “Hey, we haven’t quite gotten this right yet.” I would say what I’ve recognized is that you need multiple listening devices and you need multiple feedback devices. If you are relying solely on the waterfall effect, you will fail. If you’re relying solely on grassroots efforts, you will fail. What we try to do, what I personally try to do as the CEO, is to develop as many listening devices within the organization as I possibly can, including firsthand perspective, indirect perspective, and hierarchical perspective that’s filtered through layers.

It’s a constant triangulation to see if what we’re saying and doing and the way that we’re saying and doing it in small groups of people is resonating with large groups of people. And then as you identify those gaps, you say them out loud to each other, and you try to close them. I think that is the job. There’s no perfect way to do this. And as soon as you think you’ve got it right, the only thing that you’ve done is identified the things you see and touch. You haven’t identified the many things you likely have not seen or touched, and you’ve left some area of the organization, some people in the organization, feeling as if it’s an “us and them” type of conversation.

So we just try to persistently throw ourselves at that. We’ve got the same challenge every other company does, which is getting the message to a certain part in the organization, and I think expediency has a tendency to take hold, or a lack of understanding filters through the telephone game. That’s why you need to have the mechanism that goes direct to the people and explain it to them the way that you explained it within their hierarchy, within their organization structure, and get their real-time feedback. And then have a loop to the folks to say, “This is where it’s connecting and this is where it’s not connecting.” But I don’t think it gets easier than that—at least in my experience, it hasn’t.

ESB: And that’s really what you and Todd are doing right now, right? Where you are going and talking directly to associates?

BP: Yes. This is an interesting thing, though, that I find a lot of cultures are not comfortable with this approach. When I first got to CareFirst, it used to freak out my direct report team that I would go to their teams just to have conversations with them. You’ve got to trust your leadership team. But you also have to verify. And sometimes it’s not an issue of trust. Look, there’s honest things that just break down in chains of communication even where trust exists.

We’ve got to be persistent in trying to reconnect those chains. How do we help each other get that right? And I think people start to realize that when you gather that information, you’re going to bring it back to them and work together on how to make things better. It’s not going to be punitive; you’re going to tell me what you’re hearing and then you’re going to help me figure that out and we’ll do it together. And through that, we’ll make progress.

ESB: That makes a lot of sense. Brian, you know, one of the things that we’ve done a lot with CareFirst, perhaps a little bit more than some other BELA members, is data and benchmarking. How are you using the data?

BP: I’m a big believer that you fight conjecture and hyperbole and misconception with facts. This isn’t about my opinion; it’s not even about your opinion or Ethisphere’s institutional opinion. This is about using the reality of us and of others like us, and different than us, as a lens to say, “Are we the best that we’re capable of being?”

Oftentimes when you deal in things like risk and controls that strike chords, where there’s an emotional connotation, there’s fear and anxiety, in some cases. Just defusing that with facts and information makes it more accessible to people and helps them to see the merits, but it also helps them to see what’s possible. It may be hard, but let’s look at others like us. How are they doing? What are they doing? And I think that constant reinforcement that we’re not the only people on this journey is something that has merit beyond us. Having an example beyond us that they can reflect on, I think, goes a long, long way to really crystallizing people’s sense of what’s actionable and what’s possible.

ESB: That makes a lot of sense. Brian, any advice for CEOs that are reading this or thinking about their own involvement with their ethics and compliance program? Any thoughts on how to dive in?

BP: You’ve got to be willing to hear the things that you don’t want to hear. You’ve got to treat every challenge, every objection, as an opportunity. And if you go into it with the mindset that better is possible and that the goal here is to constantly improve, then it makes you far more willing and receptive to listen to the things that organizations just don’t want to hear of themselves and individuals don’t want to hear of themselves.

People are sometimes worried about questions—“Well, why do you want to ask that question?”—because we’re afraid of what people will say. Well, you’ve already been defeated, in my opinion. If you can’t build the facility and the willingness and the desire to improve by acknowledging that there’s room for improvement, or at least be open to the possibility that people may have something that’s on their mind different than what you would like to believe to be true, how do you possibly get to the right trajectory of these things?

ESB: CareFirst has been a World’s Most Ethical Companies honoree for the last seven years, which is a very substantial accomplishment because it’s a very rigorous process that you all go through. Why is it important to CareFirst as an organization to be on that list?

BP: I mean, from my perspective, and this may not be exactly what you’re expecting, I think the designation is fabulous, but I don’t think that designation is the most important thing in this conversation.

ESB: It’s the process.

BP: The process is the way for us to determine whether or not we’re making the kind of progress we want to be making, as compared to other people. We had this conversation recently, and someone made the statement, “If we ever failed to make the World’s Most Ethical Companies list, it would be crushing to this organization.” And I said, “I’m not sure I agree with that. I’m not as sure I agree it’s the right way for us to be looking at this.” The idea here is that we need to be able to hold up a lens—not just of ourselves and what we could imagine—we need a lens that incorporates many different other perspectives on this topic, that allows us to really get to a much better trajectory of improvement, constant improvement. And this is what the process has given us. I would not feel good about not being a World’s Most Ethical Companies honoree, that is 100 percent for certain. And we’ve codified this into our business goals for each division, as well as the company, for a reason. We want people to feel this is co-equal to everything else we’re saying we’re trying to accomplish. But if you were to ask me what the benefit is, it’s what we learn every year. And every year we learn something about what others like us and those who are different than us are doing that we could be, should be, and need to be considering that we may not have fully considered.

To me, that’s the real benefit of the process—being on that journey with an organization that helps us look at it that way, but also other organizations who are, I think, trying to accomplish the same thing.

ESB: If I could have wished for an answer, that’s exactly what I would have wanted to hear. To us, it isn’t about the 130 or so companies that make the list every year. It’s about why you apply in the first place, and what it says about who you are as an organization and what matters to you.

BP: I think the risk with things like this is always that people begin to study for the exam. If you’re just studying for the exam and you’re not trying to be a great practitioner, I feel like there’s something that gets lost in translation. We wouldn’t want to just work towards the designation and not really work towards progress.

ESB: Anything that you would add that we haven’t already talked about?

BP: I’m interested to see where the journey takes us. I think the sensibility around things like ethics continues to change and evolve. And I feel like we’re in the midst of a fairly rapid change cycle. I think getting a perspective from within our associate base of what a high ethical standard means to them, and balancing that with the same perspective of outside organizations who aren’t us, is something that is worth revisiting.

Organizations are oftentimes finding too late that they failed to meet the expectations of their constituents after they’ve done something that looked to them like the standard course of business in any other year, or any other decade, but reached its expiration date in this year, in this decade. I see a lot of companies struggling with that dynamic sensibility. As a company and as an industry, I feel like that’s something that probably warrants some additional time and energy to say, “So how do we move with that? How do we incorporate that into our planning, our thinking, but also our questioning?”

ESB: I think my favorite part of this conversation has been a perspective that transformation is not a single moment in time. It has to become a mindset, and that’s a different way of thinking about the role that values play in the course of having that kind of attitude.

BP: Yes. As you talk about that on your side, I wonder if other CEOs are having that conversation. I find it feels we’re on a little bit of a horizon with that. Everybody’s beginning to give deference to that reality. But I’m not sure our constructs have really matured to address it. You’re still trying to convince people that this is a constant, this is the new norm. If you’re waiting for it to go back to being what it used to be, or what you remember it being, you’re probably not going to be successful.


About the Expert:

Brian D. Pieninck has been President and Chief Executive Officer of CareFirst BlueCross BlueShield since July 2018. Prior to serving as President and Chief Executive Officer, Mr. Pieninck was CareFirst’s Chief Operating Officer. In that role, he was responsible for overseeing the company’s four strategic business units (Consumer Direct, Small and Medium Group, Large Group/CareFirst Administrators, and Federal Employee Health Benefit Plan), as well as the company’s Technical and Operational Support division. Mr. Pieninck joined the company in 2015 and previously served as Executive Vice President for the company’s Large Group Strategic Business Unit and CareFirst Administrators. Prior to joining CareFirst, Mr. Pieninck was a member of Aetna’s executive leadership team, where he held a variety of positions of increasing responsibility during a 19-year tenure, including President of Southeast National Accounts, and most recently, President of the Americas for Aetna International. Mr. Pieninck is a member of the boards of the Federal Employee Program Board of Managers, Special Olympics Maryland, and the Economic Alliance of Greater Baltimore and is a member of the United Way’s Tocqueville Society.