The story of how one legal department is using legal operations to engage stakeholders and reduce risk.
In 2019, I graduated from Northwestern’s Master of Science in Law. After graduation, I got a job in the legal department at VillageMD, a healthcare and technology growth company. I am actually one of three graduates from Northwestern’s MSL program in the legal department at VillageMD including my peers Janessa Nelson and Gregory Amenta.
This past year, I worked with a team of people including a graphic designer, co-author Morgan Logan, to create a centrally accessible, collaborative policy management platform. This is our story of how we tackled policy and knowledge management from scratch in a growth company.
1. “Can you help me with something?”
It was just after I joined the company when I was asked by Wendy Rubas, our General Counsel and co-author for this article, to improve the VillageMD policy manual.
It seemed like an innocuous request. I didn’t realize that the project was an opportunity to design knowledge work, see Post 159 (Jason Barnwell’s efforts at Microsoft Modern Legal), and create a knowledge management system, see Post 168 (Ken Jones’s journey at Chief Legal Technologist at Tanenbaum Keale); or that this project would introduce me to so many of the concepts of legal innovation, see Post 071 (Type 0 vs Type 1 legal innovation) and the T-shaped legal professional with skills such as design thinking, technology, process/project management, and legal knowledge/skills, see Post 161 (using these skills in legal department in an effort to solve company’s supply chain issues).
At the start, I learned that Wendy had already created a policy management system at VillageMD about a year before I arrived. She had created a policy template on a word document, developed a policy numbering system, gathered existing policies, and wrote a few new ones. Because VillageMD is a growth company and was still new, it had no intranet or a policy management program. So, she created a SharePoint site where the workforce could view the policies. It seemed like a great idea at the time. I could tell from how she and others involved described the process that it had been a big effort to get all the policies finalized, formatted correctly, and stored on the site.
The problem was engagement. After a year, there were only 25 viewers to the policy site on SharePoint. If we are being honest, this was most likely visits by members of the legal department! Even worse, we started to run into situations where people were duplicating the content posted on the site because they did not know it was there. We also noticed situations where other content did not match policies, such as various forms or pieces of training that were being developed. I now realize these are common problems most companies face with their policy management platforms.
The other problem was VillageMD had been wildly successful and had several new locations and service offerings. So my task was twofold, to devise a new way to engage the workforce in our policy content, and also to lead a process of developing the new content needed for the growth and expansion of the business.
2. What is a policy and why do you need one?
We did a lot of planning at the beginning of the project to determine the best approach. At the outset, we called meetings with various departments in the company to try to assess their needs and listen to their feedback. Setting up these meetings, led to one of my first lessons in this project. No one comes to a meeting about policies!
Working in the legal department, I had learned how important policies were, and in particular, the impact they have in litigation or government investigations. But to the rest of the organization, they were an afterthought. Everyone was interested in the more glamorous subjects, like data analytics, for example. As soon as people knew that the meeting was about “policies” we wouldn’t get any traction.
The more I started to research and understand the problem, the more I became convinced that despite their bad rap, policies are critical to an organization. Data analytics is really powerful to help you identify patterns and trends, but at the end of the day, you need to be able to guide the workforce to know what to do based on what the data is telling you. In other words, as our opening graphic suggests, we needed to embed these insights into a written policy.
We became aware that the policies are actually reflective of the various decisions leaders have made. So, we started to change our language and to refer to the project as a way to communicate “Decisions” not to publish “policies”. Throughout the article, if you replace the word policy with the word decision you can see how this has an impact.
3. Our lightbulb moment: “Why aren’t your policies open source?”
Solving the problem of user engagement was the first order of business. Our lightbulb moment came after a chance encounter with someone from the technology team at VillageMD. He asked us why our policies were not “open-sourced”?
To be honest, I did not know what he was talking about! But this question felt like an opening and eventually lead us to a new way of thinking. We started to get curious about the processes used by the tech team to manage projects. They use a wiki space to collaborate and share information on the various projects they have in development. This allows them to be collaborative but also to be nimble and make frequent changes as they go. We started to ask ourselves how we could open up policy content and how to make a policy system collaborative.
This led us to explore how to use a wiki space to reimagine policy management. At this point, we settled on three guiding principles for the project. If you are familiar with the T-shaped legal professional, these look familiar!
Guiding Principles for Policy Management at VMD
- Engaging. Our workforce will be able to interact and engage with the policy content (rather than just be told what to do). For clarity, the workforce users cannot change policy on their own. But rather they can provide input and content suggestions in real-time and can see each other’s feedback. Conceptually we were thinking about the webpages you encounter that ask a user “did this help answer your question” as a guide to how this could be useful.
- Visual. Wherever possible our policies would be visual. The best wiki pages have charts and graphs – and not just words and we reviewed lots of information about how pictures can make a better impact than words. See Post 137 (PhD data scientist Evan Parker relating how he learned to communicate with lawyers). So, we wanted to use graphic elements as much as possible. We were inspired by Radiant Law’s guiding principles for knowledge management. See “Knowledge management principles,” Radiant Law Blog, June 19, 2019 (warning that “[d]ocuments are coffins where information goes to die, and document management systems are graveyards”).
- Holistic. Since no one comes to a party about policies, we decided we did not want the site to be a “policy” site. Instead, we wanted to bring together other types of related content, including training and forms, and make them easily accessible. We determined that policy content is closely related to the content of training, and also to the content in various company forms. Often in organizations, these are managed by different people and even stored on different systems. (There is an LMS system for training, a policy system for policies, and a separate place to get forms.) Linking together training, forms, and other organization content so that they are unified and easily accessible would be a breakthrough.
- Project management. Wendy (the General Counsel) impressed upon me the need for planning and project management. She mentioned (repeatedly) that she had done policy projects before and that half-way through realized that the system for managing content wasn’t working and everything was a muddle. My marching orders were to have a meaningful way to track the content in various stages (draft, reviewed, final, archived). She also wanted me to be able to produce a concise scorecard of progress that showed who had their policies done. The scorecard needed to be automated so that we weren’t manually counting and sorting things. This proved invaluable. (People may not be motivated to write their policies, but they don’t want to be a red light on a company scorecard!)
4. Creating “Polly”
After a lot of debate, what felt like a 1,000 planning meetings, and extensive project planning we started the project and affectionately named our wiki space “Polly”. Polly was personified so that you could say “Just ask Polly”.
The name Polly was also supposed to reference the concept that a policy is an old-fashioned remedy but sometimes even more effective than the new-fangled and trendy things like machine learning and data analytics.
Right from the beginning, we had a number of unexpected challenges.
a. Visual table of contents
We wanted the policy content to be visual, but we also had to think about the way a user navigates through the various policies. We decided we wanted the user to be able to navigate the content visually – in a geospatial relationship to where it belonged in the organization. In other words, instead of the old “table of contents” we created a clickable image of our organization – inviting the user to click to the area or department they were looking for.
Once a user selects the branch of the company, they then choose the department—again in a geospatial format. So for example, for corporate services, we used isometric floor plan images so the user could click on any of the departments located to access the policies specific to that department. Beyond just looking way better it allowed us to create filters to separate our policies in a way that makes sense to our workforce.
One thing that we did not expect was how much people would care about the picture that represented their department! Even though no one wanted to come to a meeting to discuss their policies, they all had opinions about their department picture on the home page!
For the clinical branches, the policies are organized in a picture of the clinical environment. Here’s an example of our Village at Home division. The clinical environment is the patient’s home because this branch is an innovative program providing primary care within patient homes.
b. User-focused policies
To meet our goal of having the policy content be visual, I was tasked with meeting various leaders and helping them produce their policies and post them in Polly. This involves three steps:
1) write long-form policies;
2) summarize the key content that users need to know; and
3) devise a picture to summarize policy content.
We started by doing legal and compliance department policies first in order to figure out how this process would work. Here is an example of how we translated one of our legal policies. Our legal department, like many, has a policy on what to do in the event of a government investigation. The policy is several pages. But after we really looked at the content, we determined that key information people need to know is much shorter. Morgan, our legal department graphic designer, created the image below (Morgan likes Gifs, and after an initial protest from Wendy, we convinced her to agree — who does not like moving pictures, right?)
We knew that some people would want to see the full policy content, not just the picture. So we created an option that allows the user to click through to read the whole policy.
Here’s a view of one of our first completed pages.
Once we had our legal department pages done, I set up meetings with various policy owners (usually a Director or VP of a corporate department) along with Morgan.
Like most projects, it turns out it more challenging than expected. First of all, it is hard to get busy people to find time to write policies. But once they do, it was even harder to get them to do a summary or think of a picture. After writing the full policy, some were very attached to the language and wanted to post the entire thing. Some even seemed offended at the very idea! “You want me to do what?”
It was also hard to convince people that we could help them get things done. At one point we were falling behind our schedule and we needed to communicate with the organization about the ways we could help them. Morgan and I created this for Wendy to present at a leadership meeting. It describes the way we wanted leaders to think about this way of communicating.
c. “What does the user need to know”?
By the end of the project, we had perfected the process and evolved the way we approached leaders.
One of the keys was the evolution of “policy” pages to basically departmental scope pages. To get this done efficiently, we devised an interview tool to walk a leader through the process based on user-focused design concepts. Rather than asking them to “design a policy page” we would guide them through questions about their department. For example:
- “What are the key functions your department performs?”
- “Who are the key personnel in each department?” and
- “What are the questions that people most often call you to ask?”
5. Content management: collaboration and collection
As we started the process of setting up the new system. We noticed that sometimes different departments had duplicate or conflicting content.
For instance, the billing and collection team had procedures for online payment that overlapped with our technology team’s policies on security. We needed a better way to navigate the content across and between departments.
We decided to set up a committee comprised of key leaders from each department and we called it the “MegaCounsel”. (Maybe people will come if we give it a cool name?) Knowing the dread that policies create in people, we promised members that there would only be six meetings, one per month for six months. We even made a game board, so they would be able to see our progress.
I was tasked with organizing the committee and keeping all the content moving. Each month, I would send packets for review and ask the committee to bring any questions and revisions to be discussed at the meeting. Finding time to bring all these people to a meeting is challenging enough but asking them to read policies beforehand is downright impossible. At our first meeting, no one had even read the policies.
Our team went back to the drawing board to get creative. These were all competitive folks who had taken on the challenge to work at a growth company and face the challenges of innovating in healthcare. So, we decided the best way to get them to read policies was to turn it into a competition.
Before our next meeting, we let folks know we would be giving prizes to the most engaged! At the next meeting not only had folks prepared better but we were getting input from across different departments questioning policies, asking for revisions, and combining or archiving policies that were redundant. Throughout the meeting, we made sure to emphasize those who contributed!
Now as we approach Month 5, the group dynamic has shifted to where people almost look forward to these meetings. There is a certain pride to being key leaders tasked with the decision-making authority of the organization and folks take this very seriously. Many bring marked up policies with questions or ways the policy can be improved. We are also really good on attendance as we have representation from almost all our departments. Thanks to the efforts of the MegaCounsel, we have been able to fine-tune our policies and our Polly pages better reflect current practices.
After the months spent in meetings, creating pages, and getting buy-in across the organization, we were nearly ready for our full launch. We had taken a boring barely used policy site and created this whole new system. But we did not want all this work to go to waste—and the memory of the 25 viewers on our first system loomed large!
How can we get people to interact with Polly and more importantly keep interacting? We decided to launch the system with a couple of contests to make sure users would browse through the different pages and see all the information they could now access.
a. Best Page Contest
First, we wanted to recognize the hard work of the department leaders who had spent time adding their policies, user profiles, the scope of services, and the multitude of other guidelines, toolkits, and documents to their pages. We asked users to go check out each page and like the pages they found to be the most creative, informational, and/or interesting. At the end of the month, we would give an award to the department with the most liked page.
b. Active User Contest
Next, we wanted to recognize the power users on Polly. For that, we gamified the platform by purchasing an add-on. As folks use the system, they are awarded points when they liked, commented on pages, followed other users, accessed the system at certain times, and by completing other achievements on the site.
We even use the gamification to send out virtual medals awarding additional points when folks helped to improve Polly. For this contest, those users who had the most points at the end of the month would be awarded for their dedication to Polly.
The add-on even came with a cool overview to track your points and awards!
7. Launching our “World Premier”
Finally, all the work that had gone into Polly was ready to be shared with the organization. To say I was nervous would be an understatement.
Unfortunately, due to the pandemic we could not host an office party and roll out the red carpet – so we made a video – and called it the WORLD PREMIER Launch of Polly. It was parody informercial and framed Polly as a product that you must have. Be sure to watch it here.
The reception to Polly was amazingly positive.
In May, we had 7,500 views on Polly and for an organization with 1,800 employees that is pretty impressive. Furthermore, we have been averaging 250 unique viewers every day.
Folks really took to it and have made it a part of the company culture. Since launch, we have been adding multiple pages a week as more leaders realize the potential of centrally located resources to share information across the organization. We have also seen many folks view the policy pages and share the policy links with their departments.
8. Where we think this could go
While we are happy with this reception, we still have a long way to go with all of the content we want on Polly. More of our leaders are recognizing Polly as a hub for their content and we are getting more requests than ever to create pages to house their materials. As we grow, we also want to make sure Polly does not become stale. As more content, is added we are focusing on ways to keep it constantly updated and avoid conflicting information from being shared.
Polly started as the legal team’s solution to sharing the organization’s policies and procedures but what is has shown us and the rest of our organization is how beneficial it can be if you can find the right way to share the company’s knowledge with their workforce.