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Prognosis for Excellence: A Look Inside MetroHealth’s New Code of Conduct

by Sarah Partington

MetroHealth is an integrated healthcare system founded in 1837. The system consists of four hospitals, four emergency departments and more than 20 health centers and 40 additional sites throughout Cuyahoga County, Ohio, employing more than 600 doctors, 1,700 nurses, and 7,800 employees. MetroHealth plays an essential role in the region, caring for all patients, regardless of their ability to pay. Earlier this year, MetroHealth published its new Code of Conduct, which aims for new levels of engagement, interactivity, and clarity as it provides employees with a valuable reference for expected policies and standards.


A Code of Conduct can be a showcase piece that represents who you are as an organization – culture, values and mission – to the world. Of course, achieving this is no small feat.

Using technology and getting creative can transform dull standards into a more dynamic and engaging experience. In this article we will discuss how we’ve been able to make that happen over several years.

Any effective compliance program requires a comprehensive Code. The Code outlines an organization’s principles, policies, and the ethical behavior expected of employees. Codes range in variety. Some list the rules in a policy style while others incorporate a more interactive approach by utilizing decision-making guides that apply concepts to real-life situations. Others use a resource document that provides a summary of the rules together with specific examples.

A Code can be more than a regurgitation of expected behaviors. It can convey an organization’s culture and act as an engagement and recruitment tool. We wanted to develop a Code that employees would want to read and act as a reference tool that employees would go to first about policies and standards.

Four years ago, The MetroHealth System (MetroHealth) began to transform our Code. It had been an 8-page, single-spaced, policy-laden document. Wanting more than a list of rules, we researched Codes and found organizations that did more than list expectations. Best Buy and PepsiCo, for example, have Codes that convey ethical behaviors expected of employees while celebrating their values and culture.

With the assistance of these Codes, we envisioned a multi-purpose Code. One that would include decision-making guides and real-life scenarios, while simultaneously conveying an ethical culture that inspires our employees and illustrates to external stakeholders our dedication and commitment to doing the right thing.

Before we could move beyond our existing Code, we had to identify our options and map out a plan. We classified four generations of Codes:

  • First-generation Codes: lots of words and rules; written by lawyers, for lawyers.
  • Second-generation Codes: still wordy, but use of images and color to divide topics.
  • Third-generation Codes: may be a pdf with active links, less words, more images, headlines.
  • Fourth-generation: a web-based platform with additional enhancements such as videos, interactive components, interactive frequently asked questions (FAQs).

After exploring the options, we chose a two-phase transition that would culminate in a fourth-generation Code (interactive portal). The first phase involved transitioning to a third-generation Code (dynamic pdf). With the assistance of a third-party, we refreshed the Code and introduced the new dynamic pdf to all employees via live training. The 2018 Code consisted of a 64-page spiral bound booklet and a dynamic pdf available on our internal and external webpages.

The new design resulted in a longer Code, but the incorporation of images, icons, headlines, and key points provided the necessary content in a manner that resonated with employees.

In 2020, we initiated the second phase of the transition. The dynamic pdf version of the Code remains the backbone of our Code to this day, but there are limitations to a pdf. We partnered with a vendor to transition into an interactive experience for our employees via a dynamic, web-based platform. The platform included multiple enhancements including embedded videos, knowledge questions, interactive features, a chat bot, layered content, and pages for our Speak Up campaign, blogs and resources.

The interactive portal allowed employees to become active participants rather than passive readers. We utilized flip cards for defined terms and added interactive questions when discussing common scenarios. Additionally, we introduced Mellie – our ethics and compliance mascot and the face of our chatbot. Mellie never sleeps and always provides a friendly face to users who may need assistance navigating the portal.

Designing a Code that would resonate with employees meant designing delivery methods that would both attract and engage. By partnering with external vendors, we have produced two refreshed versions of the Code that 1) highlights the foundation of our ethics and compliance program, reflecting MetroHealth’s values and 2) provides an interactive experience that delivered education and resources easily and effectively.

Who we are as an organization has shifted. In this post-pandemic era, we have shifted our focus to be more than patient care. To that end, we’ve launched several campaigns—Equity First, More than Medicine series, and the introduction of a Chief Equity Officer in 2021.

In light of these changes, we shifted our emphasis in the Code to represent who we are. We opted to provide greater emphasis on employees. To celebrate the diversity of our employees we captured their images on the cover of our Code and throughout the document.

To capture images of current employees, we hosted a two-day photo shoot and walked throughout our organization to photograph our employees. By showcasing employees, we hope they will be excited to scroll through the Code in its entirety looking for familiar faces. We hope this generates enthusiasm and eagerness for the release of the final product.

In addition to introducing an employee-focused emphasis, we refreshed the tone and content. Transitioning away from legalese, we embraced a softer tone that would resonate with our employees. We wanted to ensure employees understand the main points of a topic. We did this by adjusting the tone, reducing the legal verbiage, and making content succinct. Revising the content to be less legal can be a delicate undertaking, but we conferred with subject matter experts (SMEs) to ensure that we did not lose the meaning.

Additionally, we maintained a consistent reading level, shortened sentences, and delivered short and simple content. The new content was more relatable and included videos, charts, and interactive questions to make the content easier to comprehend. For instance, we used a set of three icons to illustrate our three-page policy on compliance investigations. On the interactive portal, our friendly chatbot, Mellie, assists users with locating topics or contacting ethics and compliance. Recently, Mellie has expanded her duties and appears in our communications and training materials. This change allows employees to grasp concepts in the Code without be put off by the legal words and lengthy sentences.

Even though this is a public-facing document, these are standards of expectations for our employees. Our goal is to provide employees with a document that they want to read and reference while making them proud to say they work at MetroHealth.

A major refresh of the Code requires input and involvement from major stakeholders throughout the organization. Ethics and Compliance led the project with collaboration from parties, both internal and external, including:

Leadership: key to the success of our Code, as they set the tone for the MetroHealth; and we wanted to ensure that the Code captured MetroHealth’s values and beliefs.

  • External organizations: a valuable source for ideas and objective assessments. In 2021, Ethisphere assessed our Code (both the dynamic pdf and the interactive portal) and provided feedback that was incorporated into the recent refresh.


  • Marketing: a vital role to any Code refresh including providing assistance with colors, fonts, photo selection, and the layout of the Code. Recently, MetroHealth launched new branding, which included a plethora of marketing tools. Marketing was invaluable to the re-designing of the Code.


  • SMEs: provide any changes to their content, and any additional features that they would like to showcase such as videos, interactive FAQs, etc.

Through our revisions, we have developed a system to identify who needed to be involved, when, and in what capacity. An inclusive approach ensured that the content was accurate and in line with organizational messaging.

The transition to an interactive portal allows for self-directed/self-managed updates. By eliminating paper and moving to a digital Code, we can easily revise the content and update the images, including refreshing the images as new faces join the organization. The ability to easily update the Code requires an active communication plan to share new content and resources with employees. Many of our employees do not have regular computer access so we developed a multi-tier approach to ensure that they were aware of the changes.

Selecting content to revise or highlight can be difficult with a printed Code, as there is no way to know if employees look at the Code or what content they’ve reviewed. Our interactive portal includes a dashboard with tracking of, and analytics on, the content accessed. The reporting features provide us with how many unique users access the Code, the content they view and for how long. This data enables us to plan for future content as well as deliver targeted communications/training.

Maintenance includes assessing the effectiveness of our Code. We utilize two modalities to assess the Code: the interactive portal dashboard and external assessments. The dashboard provides analytics that permit us to target usage data for a specific time period. This permits us to measure the effectiveness of communications and trainings that discuss or highlight the Code. Additionally, we engage outside parties to provide an independent assessment. In 2021, Ethisphere provided an independent assessment of our Code. The assessment evaluated the effectiveness of the content, delivery, structure, and appearance. Overall, the assessment was positive and provided opportunities for improvement which we incorporated into our 2022 revisions.

Beginning in 2018, we set out to create an award-winning, memorable document that represents who we are. Over the last four years, we have dedicated time and resources to realizing that goal. We transitioned our Code from a single space policy to a digital experience that engages employees. It tells the MetroHealth story, it tells everyone who we are.



Sarah Partington, JD is Senior Compliance Officer/Director, Compliance Operations, for MetroHealth. In this role, she is responsible for overseeing key enterprise-wide ethics and compliance program functions including: policy management; hotline operations, training activities and the conflict of interest disclosure process


This article is from the Fall 2022 issue of Ethisphere Magazine. To read the full issue, click here.

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