We are all frightened by the menace that COVID-19 is emerging to be — in the United States and overseas; in the public sector and private enterprise; at home and at work. So today let’s first begin with an uplifting video from Hubei, China, about what life can look like on the far side of this threat.


Yes, this video is schlocky stuff from the People’s Daily, intended to be heart-warming propaganda that glosses over mistakes Beijing made with COVID-19 in January. Still, it is a fact that China has closed its emergency hospitals in Hubei province, where the virus started. It’s also true that China is now sending medical staff and supplies to other countries. 

I don’t know how accurate that video of smiling medical staff is, but it is accurate that China is conquering COVID-19 after steep losses early in the outbreak.

We in the West are just reaching the steep losses now. Italy entered it last week; the United States will enter it this week. We are going to see more lockdowns, more draconian in their reach, within days. 

Which brings me to our second video today: a clip of MSNBC host Rachael Maddow interviewing Donald McNeil, a health and science reporter for the New York Times who has been following COVID-19 closely.

The clip is worth watching in its entirety. The thrust is this: that China did not repel COVID-19 by locking down Hubei province; China repelled COVID-19 by using the lockdown to implement other public health measures that did

That’s my concern for corporate compliance, audit, and risk management today. Yes, our COVID-19 lockdowns will help push down infection rates and give breathing room to our hospitals. 

But we also need to consider, right now, how to integrate public health measures into our private enterprise operations when we turn the economy back on. Otherwise that engine will just keep stalling in fits and starts, and rates of infection risk going back up.

Let’s look at a simple example from China.

Thermometers and Fever Clinics

As McNeil from the New York Times explains, wherever  people in Hubei province go right now, they have their temperature taken. When you leave your apartment complex, when you get on the subway, when you enter an office building, when you enter a shop, when you get back on the subway, when you return to your apartment complex — at every single juncture, someone takes your temperature.  

If you’re found to be running a fever, everything stops. You’re immediately sent to a fever clinic, where medical staff run a series of tests to see whether you have COVID-19. If you do, you’re sent to an isolation facility. For the last two months, that would have been temporary field hospitals: sports arenas, convention centers, and the like.

You didn’t even get to go home in this scenario, because sending you home would just infect your family. Disease surveillance, followed by immediate isolation, was key. 

China had fever clinics, along with disease surveillance procedures, thanks to its experience with SARS 20 years ago — an experience the West didn’t have, so we don’t have comparable clinics. China also has an authoritarian regime, so when it decides to intercept and isolate someone for weeks on end, it can. The West doesn’t do that. 

Today in China people can move around and do business again, but COVID-19 is still a huge concern as corporate enterprises there try to return to normal. For example, factories want to resume business, but fear that one sick employee might force them to quarantine a whole shift or plant crew. So they take steps such as close supervision of employees who live in factory dorms (another institution the West doesn’t have), or monitoring of employee health. 

How will Corporate America address that same challenge, as we emerge from lockdown in six to eight weeks’ time? How will we integrate similar public health protocols into our policies and procedures for daily employee conduct and interaction with customers? 

I understand that corporate offices are overwhelmed right now just trying to address employee safety and immediate financial operations. I understand that many of us are personally anxious for our own health. Lord knows I am, with three weeks of food in a closet while I’m too nervous to eat much. 

Still, we cannot ignore the far side of the surge. We need to begin planning, right now, for wise business practices that keep us all healthy and economically productive at the same time. This belongs right at the top of the risk committee’s emergency agenda, too.

covid-19

We need to plan, now, for how business operations might need to change on the down-slope of the curve.

Practical Starting Points

OK, enough shrieking about our far-side threat. Let’s consider some practical ways to start, including some examples from compliance and audit folks who might not even know they’ve already started. 

The two concepts we want to integrate into operations are social distancing and disease surveillance. You know how we talk all the time about due diligence or ethical values, and embedding those ideas into standard operating procedure? Well, meet our new best friends in risk management lingo. Social distancing and disease surveillance. 

We will need to develop frameworks for these concepts, so we can assess our risks, find weaknesses, and introduce controls or policy changes to correct them. The Center for Disease Control, for example, has an infectious disease framework, although it’s geared more for public health agencies than private businesses. Still, it’s a place for risk assurance professionals to start learning. 

And as I said, at least some businesses are starting to grapple with this issue. 

For example, I spoke with one audit executive at a regional bank in the Rocky Mountain region. They told me, “Right now we’re just trying to address the immediate need of operationalizing work from home.” I floated the idea of bank branches taking the temperature of customers. An intriguing point, my friend said, but  “there’s been no communication about the long run.”

That’s OK for now. But my audit friend didn’t realize that when they said “operationalizing work from home” they actually were talking about integrating social distancing into daily bank operations, at least in the back office. (Reminder: FINRA published pandemic guidance just last week that touched on many of these issues, too.)

I also spoke with the compliance officer of a manufacturing concern with operations in Hubei, China. There, management workers are currently back in the office two days a week — so the office is never at more than 40 percent capacity, giving employees more space. Again, that’s social distancing implemented as policy. 

Disease surveillance and management, however, will need attention soon enough. Such as:

  • Retailers will need to think about how they interact with customers. (Example: mark one-meter squares on the floor at checkout lanes, to help with social distancing. Accept Venmo or Apple Pay at all points of sale.) 
  • Food and transportation businesses will need to consider themselves critical industries, and ponder how they can keep a healthy workforce to get fresh supplies to supermarkets. 
  • All critical infrastructure industries — telecommunications, banking, utilities — will need ways to assure a sufficient, healthy workforce. For example, all telecom technicians get a COVID-19 test at end of shift, for results by next day.

That’s enough for today about the subject. Radical Compliance will focus much more on COVID-19 for the foreseeable future; this is an urgent priority, if we want to regain anything resembling normalcy any time soon. 

So if you have ideas, suggestions, resources to share, websites to recommend, email me at [email protected]. If you have experience in public health, find me and we’ll do a podcast, or I’ll take not-for-attribution dictation and pass along your advice.

Stay well.

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