2021 Corporate Responsibility Report

Table of
Contents
Purpose..............................................................................3

Patient Feedback and Experience Surveys...............27

Operational Improvements.............................................56

Letter From the CEO...........................................................4

Clinical Innovations.............................................................28

We Are Proud Healthcare “Fixers”.................................57

Where We Provide Care....................................................5

Mental Health and Psychiatry........................................31

Consultation Services.........................................................58

Nine Things to Know About Wellpath........................6

Clinical Training....................................................................34

Philanthropic Efforts............................................................59

Leadership in Challenging Times.................................8

Pharmacy.................................................................................35

Case Study...............................................................................60

Reducing Recidivism and
Improving Health Equity...................................................10

Safe, Quality Patient Care.................................................36

Process................................................................................61

People..................................................................................37

Corporate Governance......................................................62

Workforce Diversity and Inclusion (D&I)...................39

Corporate Compliance Program...................................65

2021 Team Member Demographics............................40

Ethical Business Practices.................................................67

Talent Acquisition and Retention.................................43

Privacy and Data Security................................................68

Development and Engagement ...................................46

Procurement...........................................................................70

Health and Well-being.......................................................49

Planet....................................................................................71

About This Report................................................................12
2021 Highlights.....................................................................15

Pandemic.........................................................................16
COVID-19 Response............................................................18
2021 Key Milestones and Events...................................19
Response at a Glance.........................................................20
Case Study...............................................................................21

Team Member Safety..........................................................52

Efforts to Reduce Carbon Emissions...........................73

Partners..............................................................................53

Pollution, Waste, and Recycling.....................................73

Successful Partnerships.....................................................54

Home Office Relocation....................................................74

Everything We Do Is About
Taking Care of People........................................................23

Partner Retention.................................................................54

Responsible Recycling.......................................................74

Accreditation..........................................................................26

Industry Partnerships.........................................................55’

Performance................................................................75

Patients...............................................................................22

Letter From the CEO

Where We Provide Care

Nine Things to Know
About Wellpath

Leadership in Challenging
Times

Chapter 1
Purpose

Reducing Recidivism and
Improving Health Equity

About This Report

“One person caring about another represents life’s greatest value.”
– Jim Rohn

2021 Highlights

II

LETTER FROM THE CEO

The Path We Are On
As I reflect on the road we have traveled and the road ahead, I am
pleased that, when faced with adversity, we remain true to our
mission—to provide quality care to every patient with compassion,
collaboration, and innovation.
This year I signed the CEO Action for Diversity & Inclusion . We
are proud of our team members who reflect the populations we
serve, and of our enthusiasm to continue improving in this area.
Ours is an environment where every person is treated with respect, dignity, and compassion.

(COVID-19) vaccine was an example of transformative innovation.
We encouraged our people, partners, and patients to get vaccinated, and in September, our team member vaccination rate was 10%
higher than the national average. We also continue to recommend
and provide a vaccine to all patients when they enter our care.

TM

Providing quality care starts with compassion, which is empathy in
action. It requires understanding how everyone’s unique circumstances affect their health and quality of life. For that reason, we
partnered with Healthify to better understand our patients. Healthify’s platform enables us to identify our patients’ social needs, find
resources, and access social services to assist in their transition
from our care. Through our Wellpath Cares Foundation, we are
supporting the Morehouse School of Medicine’s work to better understand Social Determinants of Health (SDoH) as well as educate
the next generation of justice-served public health leaders.
Success in the work we do requires collaboration with community and governmental organizations. When patients need treatment outside of our facilities, they are sent to one of approximately 14,000 community providers in our nationwide network.
We partner with government agencies to provide oversight and
direction in the delivery of care in our shared environments. In
2021, we welcomed multiple local government agencies and two
state departments of corrections (DOCs) as new Wellpath partners. Our performance and alignment around reducing recidivism and providing quality care has earned us the opportunity
to continue our partnerships year after year. In fact, 95% of our
government partners have worked with us for multiple years.
In 2021, the Delta and Omicron variants presented ongoing
challenges, but the development of the coronavirus disease 2019

Among other challenges were the Great Resignation and continued
global supply chain issues. As you will see in this year’s report, we
acted boldly to face these issues head-on. Our solutions build on our
foundation and increase our pool of potential healthcare providers
while improving our quality of patient care. These include further
development of our telehealth platform, the Wellpath Healthcare
Cloud, implementation of our Travel Nurse Program and alternative
staffing models, use of our central warehouse in St. Louis for distribution of personal protective equipment (PPE), and a $21.3 million dollar
increase in pay for our team members.
As important as the path we are on, are the people with whom we
travel. I am proud of our dedicated team members who provide hope
and healing to patients. Meeting our nurses, doctors, and support
staff is a humbling experience and reveals how each one is motivated
by their concern for others. I am proud of the resilience we demonstrated in navigating this journey together, and of the direction we are
heading. My thanks go out to each member of the Wellpath family for
your incredible work and leadership in challenging times.
To hope and healing.

Jorge Dominicis
Chief Executive Officer and Chairman of the Board

/4/

II PURPOSE

Wellpath is the premier provider of localized, high-quality, compassionate care to
vulnerable patients in challenging clinical environments.

Where We Provide Care

Wellpath at a Glance1

Wellpath provides care in four primary types
of facilities:
1.

Jails – Our Local Government division
provides healthcare in local county/parish jails
and juvenile detention facilities.

2.

Prisons – Our State and Federal division
provides healthcare in state and federal prisons
and juvenile justice residential facilities.

3.

4.

Local Government Division (Jails)
• 330 facilities
• 99K+ ADP of patients

State & Federal Division (Prisons)
• 221 facilities
• 140K+ ADP of patients

Residential Mental Health Treatment
Facilities – Our Recovery Solutions division
provides care in residential mental health
treatment facilities and behavioral health/
neuropsychiatric hospitals.

Overview

Community Care Centers – Our Community Care Centers provide medication-assisted
treatment (MAT) for patients challenged with
substance use disorder (SUD) and behavioral
health disorders.

Wellpath Team Members

• Number of states: 34
• International countries: Australia
• Number of site service contracts: 308
• Number of facilities: 567
• Annual Average Daily Population (ADP) of patients2: 240K+

14.2K+ active team members3

Recovery Solutions Division
Residential Mental Health Treatment
Facilities/Hospitals
• 13 facilities
• 2.3K+ ADP of patients
Community Care Centers
• 3 facilities
• 1.2K+ patients

1

As of December 31, 2021.

2

 DP is the average population of patients at any given site contracted with Wellpath for a given reporting month. Annual ADP is the average ADP of
A
calendar months within the reporting year.

=
-=========- - ---=---=--=-======-----

3

Includes U.S. full-time, part-time, and pro re nata (PRN) employees.

/5/

II PURPOSE

Nine Things to Know About Wellpath
1.

Wellpath is exclusively a healthcare services company. Federal, state,
and local legislatures, elected officials, and the judiciary establish criminal
justice policy and administer justice. We neither participate in the disposition
of criminal justice nor own or operate correctional facilities where we
provide healthcare services. Wellpath primarily serves patients that are
the responsibility of government agencies. By the end of 2021, our few
remaining contracts with private prison operators were terminated.

2.

Wellpath does not benefit from higher incarceration rates and
our profits do not increase as facility incarcerations increase. Our
contracts are generally structured to avoid financial benefit from inmate
fluctuations. Reimbursement changes only cover costs that rise or fall
with the population, such as supplies, pharmaceuticals, and off-site
services. Our contracts often include a modest per diem payment or
credit to reflect fluctuating costs. We calculate the per diem amount
to approximately equal the increase or decrease in variable cost that
accompanies an increase or decrease in the patient population. We
prefer contracts that align with patient and societal interests.

3.

Wellpath always prioritizes patients over profit. Our business is
grounded in providing excellent service to patients and adding value
for our government partners. The health of our business rests solely on
our patients’ health, partner satisfaction, and the belief of our people
in our mission. Cutting corners to reduce cost at the expense of any
of these hurts Wellpath and increases business risk. Great patient care
helps patients and communities, lowers risk, improves partnerships,
and supports growth. Poor patient care can lead to opposite outcomes.
To demonstrate our commitment to avoid business practices that
inappropriately incentivize profit, we annually donate income from
operations exceeding 5% of revenue to not-for-profit organizations that
address SDoH and health equity.

4.

Wellpath patients receive the right care in the right place. A hallmark
of our healthcare philosophy is that patients receive the appropriate
level of care in the appropriate place, even when that requires sending
patients outside of our facilities. In 2021, we worked with more
than 38,000 unique providers. More than half of those providers are

GRAPHIC

/6/

II PURPOSE
contracted directly with Wellpath or were accessed through a shared
network agreement.
5.

6.

7.

Recovery Solutions facilities, that number rises to 100%. Newly incarcerated patients are uniquely vulnerable and fragile at the time of
care and often are in extreme emotional crisis. We offer a range of
mental health services from intake to discharge planning to provide
short and long-term solutions for those suffering from various mental health issues.

Our team members are committed to avoiding unsatisfactory clinical
outcomes. Considering the approximate eight million interactions we have
each year with patients who are among the sickest, most fragile in any
setting, bad outcomes are rare. Like any large healthcare system, Wellpath
comprises over 14,000 people who do difficult work in challenging settings,
and unfortunate situations and outcomes sometimes occur. In this, Wellpath
is not alone. We strive to provide quality care to every patient and invest in
hiring, training, planning, and developing processes, policies, and procedures
to achieve our important goal.
Collaboration is not just a part of our mission; it is critical to providing healthcare in a correctional facility. Wellpath team members are
guests in a correctional facility; we rely on close collaboration with corrections staff to do our job. Furthermore, jails and prisons are designed
to safely hold incarcerated people; in general, they were not designed
primarily for providing healthcare services. In most cases, for our healthcare staff to see a patient, a correctional officer must be available to
retrieve and supervise the patient throughout their interaction.
Correctional healthcare is vastly different from community medicine.
The settings we serve are far more challenging than those found in the community, and we serve a patient population far different from typical community healthcare settings. Consider the following:
•

•

SUD and MAT – An estimated 65% of our patient population has a
substance abuse disorder3, compared to 10% of Americans4. We offer
patients detox, MAT, and substance abuse programs for their addictions.
Our WCCCs provide MAT services for continuity of care after discharge.

•

SDoH – Having shelter is a major contributor to an individual’s overall
health. We estimate that 10% of incarcerated patients experience
homelessness.5 That compares to 0.18% for the U.S. population.6 Our
discharge planning helps connect patients with government programs
and healthcare providers to reduce this SDoH.

8.

Wellpath works to hire incumbent staff when it becomes the healthcare
provider at a new facility. When Wellpath enters a new partnership, we intend
to retain incumbent staff who are otherwise qualified, and who meet Wellpath’s
pre-hire requirements. Wellpath works with facility leaders to offer “right of first
refusal” interviews to current non-management team members in accordance
with this philosophy. We want to retain and retrain as many incumbent staff
members as possible with equal or higher pay and we offer benefits on day one.

9.

Wellpath has positive labor relations. Wellpath has worked with collective
bargaining unions since 1998. We have a positive relationship with current
unions, from California to Florida and in Australia. We support fair and consistent practices for all team members.

Mental Health – One in five adults in the community experiences
mental health issues each year1, whereas about 40% of Wellpath
patients in jails and prisons have a history of mental illness2. In our

1

h
 ttps://www.nami.org/NAMI/media/NAMI-Media/Infographics/NAMI_2020MH_ByTheNumbers_Adults-r.pdf

4

2

https://www.nami.org/NAMI/media/NAMI-Media/Infographics/NAMI_CriminalJusticeSystem-v5.pdf

5

https://www.nih.gov/news-events/news-releases/10-percent-us-adults-have-drug-use-disorder-some-point-their-lives
Council of State Governments, 2016: https://www.voa.org/homelessness-and-prisoner-reentry

3

h
 ttps://nida.nih.gov/publications/drugfacts/criminal-justice#:~:text=While%20the%20exact%20rates%20of,population%20
has%20an%20active%20SUD.

6

https://www.huduser.gov/portal/sites/default/files/pdf/2020-AHAR-Part-1.pdf

/7/

PURPOSE

Leadership in Challenging Times

COVID-19 in 2021

Impact of the CARES Act

In December 2020, the Federal Drug Administration (FDA) issued an Emergency
Use Authorization for the first COVID-19 vaccines. In the early months of 2021,
vaccination capacity rapidly increased. By April 2021, any American eligible for
the vaccine could easily obtain it.1 By August 1st, 58% of Americans had received
at least one dose of a vaccine.2 Unfortunately, vaccinations stalled, and the Delta
variant killed more than 130,000 Americans from August through October.

The CARES Act allowed hospitals to pay as much as an extra $95 per hour to
employed nurses and uncapped rates to nursing agencies and travel nurses to secure talent. This created a frenzy of hospital temporary nurse wage
increases (exacerbated by astronomical sign-on bonuses and shift differentials). As a result, many Wellpath nurses were attracted to work outside the
company, further complicating our ability to attract and retain nurses. This
crisis didn’t just happen; it has been decades in the making. The aging of
America has increased demand for nurses, a trend that will continue as the
population continues to grow older.

In December, the new Omicron variant reached the United States (U.S.). Highly
transmissible, it drove daily case rates to new highs, with a peak of nearly 600,000
by year’s end. Its high case count led to a peak daily death rate in excess of 2,000.
By December of 2021, the Centers for Disease Control and Prevention (CDC) reported that unvaccinated people were 20 times more likely to die of COVID-19.3
Multiple COVID-19 waves raised the stress level in an already stressed nursing
labor pool. An October 2021 survey by the American Nurses Foundation found
that 42% of respondents reported an extremely stressful, disturbing, or traumatic experience due to COVID-19.4

A Generational Nursing Crisis
During 2021, many nurses and other healthcare workers said, “enough!,” joining
what’s been called the “Great Resignation,” and creating the first true decline in
working nurses in a generation. Compounding the effect of this, many nurses left
the regular workforce to become travel nurses, drawn by temporary compensation
sometimes exceeding $10,000 per week. This was an unintended consequence of
the Coronavirus Aid, Relief, and Economic Security (CARES) Act and follow-on legislation, which provided some $178 billion in funding to hospitals and other providers, but was not made available to healthcare professionals in our environments.

Opioid Epidemic
In the first half of 2021, there were more overdose related deaths than ever
before. An increase in drug use, lethal synthetic opioids, and isolation and
social distancing restrictions contributed greatly to the problem.5 The opioid epidemic is felt by many of our patients. It is estimated that nearly 2/3 of
people in jails and prisons are dealing with SUD. While there is momentum
from lawmakers and community leaders to increase MAT programs throughout the country, a study from the National Academy of Sciences reported that
only 5% of people with opioid use disorder in justice environments received
medication treatment 6.

Kronos Outage
In December, Human Resources (HR) management company Ultimate Kronos
Group (UKG) was hit by a ransomware attack that directly affected over 2,000
businesses worldwide that rely on Kronos for issuing paychecks. While the outage did not compromise Wellpath data, it did affect our ability to process payroll,
handle time sheets, and manage our workforce.

1

https://www.usatoday.com/in-depth/news/health/2021/04/19/covid-vaccine-tracker-available-widely-hesitan- cy/7187382002/

4

https://www.nursingworld.org/~4aa484/globalassets/docs/ancc/magnet/mh3-written-report-final.pdf

2

https://usafacts.org/visualizations/covid-vaccine-tracker-states/

5

3

https://www.thedenverchannel.com/news/national/coronavirus/unvaccinated-people-20-times-more-likely-to- die-ofcovid-cdc-says

https://www.commonwealthfund.org/blog/2022/overdose-deaths-surged-first-half-2021-underscoringurgent-need-action

6

https://nap.nationalacademies.org/catalog/25310/medications-for-opioid-use-disorder-save-lives

/8/

II PURPOSE

Our Response
Effective Patient Care
Our justice-involved patients have a constitutional
right to receive appropriate healthcare. Respectful of
this right, and respectful of the special needs of our
vulnerable and medically complex populations, we
take our responsibility to deliver quality care seriously,
even in the face of extreme circumstances. In 2021,
our front-line healthcare workers and leaders dug
even deeper than in 2020 and delivered care that
mirrored community trends in terms of COVID related
datapoints. Our ever-improving care, which included
vaccinations, testing, medications, quarantine, and isolation, resulted in a 41%1 reduction in average weekly
COVID-19-related hospital admissions from 2020.

Allocated Resources
In 2021, we invested an additional $21.3M toward
our people. This included bonuses, temporary pay
increases, and our Financial Outreach to Clinics Under Stress (F.O.C.U.S.) initiative. These bonuses, wage
increases, and temporary differentials in cooperation
with our custody agency partners supplemented base
compensation for nurses in many of our locations.
We offered one-time bonuses to site leaders, such
as health service administrators (HSAs), directors of
nursing, and regional directors of operations (RDOs),
to recognize their extraordinary commitment. We
created “the new normal” for healthcare employment by adjusting team member wages and moving
them into the top quartile for compensation whenever possible. In addition to our other initiatives, our
F.O.C.U.S. dollars are specifically targeted to increase
pay differentials and bonuses to nurses and other essential team members in our most affected commu-

nities. We distributed $6.8 million in December 2021
through this initiative, which will continue into 2022.

Alternative Staffing Models
Correctional healthcare providers, like Wellpath, were
not eligible for CARES Act funding, and therefore needed
to take action to ensure we had the talent necessary to
provide quality care to our patients. Wellpath is executing
a multi-pronged strategy that includes the development
of alternative staffing models. Employing a wide range
of care providers to expand service capacity of nursing
teams like medication administration, vital sign collection, electrocardiogram (EKG), and phlebotomy, is a key
strategy in developing alternative staffing models.
Our alternative staffing models are compliant with
state laws and regulations and mirror trends seen in
recent years in the medical profession (for instance,
the delegation of duties to non-nurse surgical technologists, etc.). When developing these models, we
kept a keen focus on patient safety and quality of
care while working to expand the pool of employees
available to provide care during these extraordinary
times. Wellpath is also continuing to develop a “super floater” pool of internal travel nurses to support
clinics. We have also expanded the capabilities and
use of our Wellpath Healthcare Cloud, reducing the
reliance on locally scarce labor where possible. Wellpath Now, which is part of the Wellpath Healthcare
Cloud, enables our patients in critical condition to
be seen by an emergency department (ED) provider
in approximately five minutes.2 This wait is drastically less than in a typical ED setting. Combining our
telehealth encounters and online specialty referral
consults, our remote provider teams conducted
more than 480,000 telehealth interactions in 2021.

1

Calculated using data from sites managed by our Electronic Records Management Application (ERMA) Care Management (CM), which includes >80% of our ADP.

2

Wellpath Now average wait time to be seen by a provider is approximately five minutes.

$28.7M
invested in COVID-19 relief initiatives

Increasing Access to Treatment
Addiction is a disease, not a crime. For people with
opioid use disorder, MAT is a clinically effective treatment which involves a combination of counselling and
clinically proven medications such as buprenorphine,
methadone, and naltrexone. In 2021, we worked with
our partners to begin or expand MAT programs in their
facilities. Approximately 50% of our local government
partners with MAT capabilities have expanded their
programs to allow for the diagnosis and treatment of
new patients. Additionally, we prepared to open three
new WCCCs in 2022 to be able to seamlessly provide
continuity of care and continuation of MAT treatment to
our patients after they leave justice-involved facilities.

Kronos Incident Response
In response to the Kronos outage, nearly overnight, a
multi-disciplinary team made up of 40+ key Wellpath
leaders from HR, Payroll, Information Technology
(IT), Legal/Risk and Communications, worked around
the clock, foregoing their holiday vacations, to rapidly
stand-up alternative, in-house timekeeping and payroll systems to ensure team members received their
paychecks. This tremendous team effort enabled us
to process approximately 27,000 payments by hand.

/9/

II PURPOSE

Reducing Recidivism and
Improving Health Equity

@

wel path
ca es
.

-

l J-

foundat1on

grants to non-profit charitable organizations
which address disparities of care that help
reduce the impact of SDoH and improve the
lives and healthcare of vulnerable populations. In
2021, Wellpath donated $1 million and provided
substantial in-kind support to the Foundation.

Each year, Wellpath engages in approximately eight
million interactions with some of the nation’s most
vulnerable and often overlooked patients. Many
of our patients have experienced
As of December 31, 2021,
severe trauma, neglect, and poor
the Foundation’s Board of
Wellpath
living conditions. We set out every
Directors approved donations
donated
day to help those who need it
to two programs run by
most and to break the cycle of
the Morehouse School of
$1 million
recidivism and improve health
Medicine in Georgia, one of
and provided
equity. Every patient should have
four historically Black medical
substantial inthe opportunity to be healthy,
schools in the U.S. The
kind support to
regardless of social strata.
Foundation provided funds to
Health inequities are reflected in
the Foundation.
the Master’s of Administration
differences in lifespan; quality of
in Justice-Involved Care
life; rates of disease, disability, and
(MAJIC) Program and the
death; severity of disease; and
Kennedy-Satcher Center for Mental Health Equity
access to treatment. We also focus on SDoH, the
(KSCMHE).
conditions in the places where our patients live,
The MAJIC program offers a master’s degree in
learn, work, and play, that affect a range of health
Justice-Involved Care and an affiliated Justice-Inrisks and outcomes. Our goal is to help our patients
volved Life Coach Certification to corrections
improve their health and quality of life so that they
professionals, which teaches students how to
will leave, start anew, and never need to return.
reduce recidivism, promote rehabilitation, and
Wellpath Cares Foundation
support justice-involved individuals.
In 2021, our Board of Managers (The Board)
The KSCMHE is producing a series of webinars
authorized the establishment of the Wellpath
focusing on care of incarcerated individuals and imCares Foundation. This tax-exempt non-operating
proving mental health, substance abuse, and health
independent foundation is affiliated with and
equity services to formerly incarcerated individuals
funded by Wellpath. The Foundation makes
to reduce recidivism.

/ 10 /

II PURPOSE

Healthify Partnership
A key to lowering recidivism is the successful discharge transition of our
patients to critical community services, such as housing, employment,
substance abuse treatment, and mental health services. In 2021, Wellpath
proudly partnered with Healthify, a leader in analyzing SDoH patient data, to
identify appropriate and accountable community-based organizations and
create plans to meet the social needs of our discharged patients. Healthify
takes a deep dive into the social service landscape in each community to
develop strong relationships with local organizations.
Our goals in partnering with Healthify are to reduce recidivism and improve
health equity by:
• Using Healthify assessment tools to establish a baseline of SDoH needs.
• Improving visibility in post-discharge social service utilization and referrals.
• Improving social risk assessments by providing a common assessment tool,
with as much integration into our Electronic Health Record (EHR) as possible
to streamline assessment workflow.

• Improving navigation to social services by using Healthify’s social service
directory of community-based organizations.

Access to Care
Wellpath continues to invest in communities throughout the country to expand
access to quality healthcare. Wellpath Community Care Centers (WCCCs)
provide evidence-based MAT and SUD programs for individuals struggling with
addiction to opioids or other substances, including alcohol, methamphetamine,
cocaine, hallucinogens, and tobacco. These services are available to anyone
in the community, with a special emphasis on providing continuity of care for
justice-served patients after release from jail or prison.
Additionally, in 2021, we broke ground on our first neurobehavioral hospital
in Palm Beach, Florida. At this facility, each patient will be provided with
holistic behavioral healthcare using a fully integrated interdisciplinary team
approach. The team’s goal is to consider the individual complexities of
each patient and personalize treatment plans for optimum outcomes. Two
hospitals will open in 2022 and serve patients from the community.

/ 11 /

II PURPOSE

About This Report
This report demonstrates our public commitment to our mantra – “Always Do
The Right Thing” for our people, patients, partners, and planet. We have organized
this year’s report into eight chapters as we did last year. These include Purpose,
Pandemic, Patients, People, Partners, Process, Planet, and Performance. We have
identified the environmental, social, and governance (ESG) risks and issues most
significant to Wellpath and our key stakeholders to create this report and reaffirm
our commitment to this process. We will continue our focus on transparency; not
only in areas where we excel, but also where we experience challenges, as a way to
hold ourselves accountable to our mission and vision.
Our responsibility for patient care almost always includes the direct provision of
on-site care (physician, nursing, pharmacy, labs, and testing). This responsibility
typically extends to coordinating and managing off-site medical services, including in-patient hospitalizations. For these off-site cases, we develop and manage a
network of providers in the community to provide
services, manage claims, and process timely payments to providers.
Our Local Government and State and Federal
divisions feature correctional healthcare operations consisting of on-site care in residential justice-served facilities, including jails and
prisons. This care may include somatic, mental,
and dental healthcare. Providing care in these
environments requires coordination with custody,
food service, maintenance, and other staff that
are not Wellpath team members. Wellpath does
not own these facilities; we are the partner that
delivers and/or facilitates the delivery of healthcare treatment to patients.

Our international operations includes Correct Care Australasia which provides
care for adult and juvenile offenders at 16 locations in Australia. It has operated
for over 20 years.
We established the disclosure topics included in this report by considering material issues defined in the Value Reporting Foundation’s (VRF) Sustainability Accounting Standards Board (SASB) standards for the Health Care Delivery and Managed
Care industries and the United Nations Sustainable Development Goals (UNSDGs).
We used these standards and frameworks for assessing the material risks and
opportunities for our company. While the contents of this report have not been
externally assured, they have been reviewed and approved by management and
our ESG Steering Committee.

Our mission is to provide quality care to every patient
with
and innovation.
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provide qualitycollaboration,
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with compassion, collaboration, and innovation.

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Our Recovery Solutions division provides care in
residential, forensic treatment facilities, government-sponsored civil commitment mental health

facilities, neurobehavioral hospitals, and community care centers. Services can
include outpatient substance use disorder treatment, mental health treatment,
and patient-centered healthcare navigation support. We provide food service,
maintenance, safety, and off-site care as needed.

308 site service contracts in
34 states and Australia

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Our People

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Over 14,000 team members

Each year Wellpath conducts an estimated
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Community
Centers
(3)
Centers
(3)
Recovery
Solutions
Recovery
Solutions
Division
Division

)

Quality care
Quality
carep
to every
to every p

Over 14,000 team members
Our People

Over 14,000 team members

Our Pati

Our Pati
Each year Wellpath
con
eight
patient con
int
Each million
year Wellpath
of our
nation’s
most
eight
million
patient
intv
of our nation’s most v

/ 12 /

II PURPOSE

UNSDGs

SUSTAI A
DEVELOPMENT

GAS

Our mission also supports the UNSDGs which explicitly call on all businesses to apply their creativity and
innovation to solve sustainable development challenges. We have reviewed the 17 goals supporting peace and
prosperity for people and for the planet. We are aligned on all and we have found business relevance on six, as
illustrated below. Wellpath is committed to prioritizing these and will continue to update in future reports.

Ensure healthy lives and promote well-being
for all at all ages
Wellpath key issue(s): Team member health and well-being,
quality patient care, mental health, patient safety, suicide
prevention and awareness, substance abuse and MAT, and
COVID-19 response

Achieve gender equality and empower all
women and girls
Wellpath key issue(s): Diversity and inclusion

Reduce inequality within and among countries
Wellpath key issue(s): SDoH and recidivism reduction

Ensure inclusive and equitable quality
education and promote lifelong learning
opportunities for all
Wellpath key issue(s): Team member development and
engagement, academic affiliations, and philanthropic
efforts

Promote sustained, inclusive and sustainable
economic growth, full and productive
employment and decent work for all
Wellpath key issue(s): Team member health and wellbeing, team member development and engagement,
talent acquisition and retention, and successful
partnerships

Promote peaceful and inclusive societies for
sustainable development, provide access to
justice for all and build effective, accountable
and inclusive institutions at all levels
Wellpath key issue(s): SDoH and recidivism reduction

/ 13 /

II PURPOSE

We identified material ESG topics by
understanding the needs and perspectives
of our people, patients, partners, and other
key stakeholders. We performed a peer
benchmarking and industry landscape
assessment to establish our universe of material
risks and topics for inclusion in this report. This
report includes the following ESG pillars:
• Environment – Planet
• Social – Patients, People, and Partners
• Governance – Process
This report accurately reflects the general
information and concepts presented. However,
it does not convey every criterion of care or
patient outcome on a granular level, nor is it an
exhaustive listing of our services, commitments,
or business operations. We prepared this report
utilizing our usual accounting methods, but
we do not represent that we utilized generally
accepted accounting principals (GAAP) data.
Our materiality matrix depicts a summary of our
2021 materiality assessment. We will continue to
engage key stakeholders through patient, team
member, and partner surveys, and investor and
board dialogue for periodic updates.

Importance to Stakeholders / Impact on Society | Increasing Importance

Material Topics

• Accreditation
• Patient Feedback & Experience
• Philanthropic Efforts
• Reducing Recidivism
• University Affiliations

• COVID-19 Response
• Diversity & Inclusion
• Privacy & Data Security
• Quality of Patient Care
• Successful Partnerships
• Suicide Prevention & Awareness
• Talent Acquisition, Retention, &
Development
• Team Member Health & Well-being
• Understanding & Improving SDoH

2021 MATERIALITY MATRIX
• Corporate Governance
•C
 arbon Emissions

• Ethical Business Practices

• Pollution, Waste, & Recycling

• Risk Management & Compliance
• Technological Innovations

Importance to the Business / Impact on the Business | Increasing Importance

/ 14 /

II PURPOSE

0
74.6%
team member vaccination rate as
of September 20211

$202K
distributed to team
members through our
Dare2Care program

480K+

data breaches involving patient,
people, or partner information

telehealth interactions

donated to the Wellpath Cares
Foundation

2021 HIGHLIGHTS

2.5K+

78.1%

$28.7M

electronic assets
recycled

of our workforce is
female

invested in COVID-19
relief initiatives

41%
reduction in COVID-19 weekly
hospital admissions from the
previous year2

1K+
internal promotions

1

Self-reported as of September 2021 based on a 79.8% participation rate.

2

Calculated using data from sites managed by our ERMA CM which includes >80% of our ADP.

$1M

105
compliance incident reports
investigated and closed

700+
incumbent team
members retained from
new contracts

401
patient lives saved with Narcan®

/ 15 /

PANDEMIC

COVID-19 Response

2021 Key Milestones
and Events

Response at a Glance

Case Study

Chapter 2
Pandemic
“Never give up, for that is just the place and time that the tide will turn.”
– Harriet Beecher Stowe

/ 16 /

II PANDEMIC

The COVID-19 pandemic has been a formidable
challenge for the healthcare industry, especially
correctional healthcare. We have learned much
over the past two years and the learning continues. We understand the importance of testing,
social distancing, masking, and protecting our
supply chain. The Wellpath strategy has been
tested and passed, even through the uncertainties that accompanied the Delta and Omicron
variants. We have incorporated this experiential
knowledge into our ongoing infectious disease

.. I

WE CAN
.
IJ0@--7H
"JS

1•

management procedures. We continue to rely
on sustained, informed, and aggressive leadership on our path to protect the health of our
patients, partners, and people.
Wellpath follows guidance from the CDC and
state governments to maintain a high state
of readiness to act while providing the best
outcomes for our patients and the resources
needed to maintain the highest standards.

~

L....1111111111
/ 17 /

II PANDEMIC

COVID-19 Response
In 2021, our COVID-19 response was steadfast. We required and provided N95
masks for our front-line workers, continued to practice social distancing as much
as possible in a correctional environment, and maintained close awareness of
new and current COVID-19 patients every day. We tested team members and
patients in accordance with recommendations from the CDC. We modified quarantine and isolation guidance to keep patients safer and respond to the staffing
shortages. Despite occasional outbreaks, our partner facilities, staff, and patients
remained safe. Our vigilance has never wavered.
During the pandemic, frontline
Wellpath team members
continued to sacrifice and
overcome personal and family
challenges to ensure our patients,
partners, and team were as safe
as possible. Preventive measures
were guided by senior clinical and
operational leaders, many with
infectious disease experience,
who provided clear, calm, and
consistent communications to
our medical teams.
Our primary goals have not
changed. During the pandemic, we
continued to provide quality care
for all patients, identified infected
patients, and prevented the spread
of the disease to the best of our
ability. In addition, we established
emergency procedures, monitored
staff and partner exposures, and
collaborated with community
health officials.

“I would also like
to highlight your
staff responsiveness
during the pandemic.
Your staff provided
medical guidance and
supplies (PPE) during
the early stages of the
pandemic. Thanks
to them, we were
able to deal with and
handle certain fears
and concerns from
my staff as well as the
offenders.”
Evan Joseph, Warden,
Richmond County
Correctional Institution,
Augusta, Georgia

/ 18 /

II PANDEMIC

2021 Key Milestones and Events
Throughout the COVID-19 pandemic, Wellpath clinical leaders followed CDC guidelines in our clinical practices and processes. Key milestones from 2021 include:
• Our COVID-19 Executive Task Force monitored and led our response to the
pandemic by providing direction and action to patients, partners, and staff.
• O
 ur physician and executive leaders led internal clinical huddles to share
information, provide guidance, address emerging issues, and answer questions in real-time.
75
• W
 e ensured COVID-19 Emergency
Preparedness Plans for partner sites
were up to date.

• We implemented measures to comply with county, state and federal healthcare worker mandates that were enacted during 2021. County and state
mandates impacted 28% of our workforce, while the federal Centers for Medicare & Medicaid (CMS) mandates affected an additional 2% of our workforce
as of December 31st. We implemented measures to comply with these mandates, including preparing communication to employees, processing medical
and religious exemptions, and anticipating and addressing staffing changes.
We will continue to monitor legislation and prepare accordingly.
• Our Chief of Psychiatry, Dr. Cassandra Newkirk, participated in a targeted educational session in 2021 for internal clinical leaders promoting and
encouraging COVID-19 immunizations to employees and patients. Our goal
was to continue promoting team member and patient vaccinations. We will
continue to be vigilant and take a long-term perspective to preserve the
health of our patients, health staff, and correctional staff.

• W
 e marshaled PPE50
and supplies and
opened a centralized warehouse in St.
Louis to supply seven million PPE items
to facilities around the country.
0 masks and turned our
• We overcame the worldwide shortage of N95
attention to overcoming shortages of protective gloves, sharps containers,
and hydration drinks.

• We increased the use of telemedicine to provide safe and effective patient
care, facilitating more than 480,000 telehealth interactions through our
remote care system.
• We provided additional support to our team members including extra sick
time, free primary care, free mental health telemedicine, child and eldercare,
academic support, and tutoring resources.
• Our senior governmental affairs and operations leaders conducted wide
outreach at all levels, from local government to the White House, as well
as numerous health and human service departments across the country
to raise awareness of the need for PPE, testing, and vaccines in correctional facilities.
• We initiated an email and site level outreach campaign to identify the status of
vaccinations for Wellpath personnel. The “Drive to 75” program asked employees to update their vaccination status with the goal of 75% vaccinated. By
September, we reported a 74.6% team member vaccination rate 1.

1

Self-reported as of September 2021 based on a 79.8% participation rate.

Our Chief Psychiatric Officer Cassandra Newkirk, MD, participated in an educational session
promoting and encouraging COVID-19 immunizations to employees and patients.

/ 19 /

II PANDEMIC

Response at a Glance

Clinical outcomes
Due to improved care, as compared with 2020, we had a 56% increase in
patient COVID-19 diagnoses, a 34% decrease in patient mortality rate, and
a 41% reduction in average weekly COVID-19 related hospital admissions.1

Vaccinations
Team Member
Vaccination Rate: 74.6%
as of September 20212

Dollars
invested
Our 2021 COVID-19
response to meet patient
and team needs: $28.7M

To ensure the delivery of efficient and effective care in 2021,
we conducted more than 480,000 telehealth interactions.

1

Calculated using data from sites managed by our ERMA CM which includes >80% of our ADP.

2

Self-reported as of September 2021 based on a 79.8% participation rate.

/ 20 /

II PANDEMIC

Case Study
COVID-19 in Alameda County
Wellpath worked diligently to prepare the Alameda County Santa Rita Jail (SRJ) for the arrival of
patients and others with COVID-19. We proactively
implemented COVID-19 precautions before the
pandemic impacted the SRJ. We developed a priority outbreak plan, which mimicked a rapid triage
response model. Early planning and intervention
with Wellpath, the Alameda County Sheriff’s Office
(ACSO) and the Public Health Department led
to process development and a robust response,
which exceeded community standards.
As a result of these efforts, the COVID-19 pandemic
has had a minimal impact in this large jail. There
have been no negative outcomes in our patients or
our people and there have been no COVID deaths
at the SRJ to date. Alameda County officials and
court experts have lauded the collaborative efforts
that led to this successful outcome. Our Master
Outbreak Plan for the SRJ has been so successful
that other California counties used it to guide their
response to the pandemic in their facilities.
Additionally, we collaborated with the Alameda
County Public Health Department and the ACSO
to publish a manuscript on the epidemiology of
coronavirus disease in a county jail. The manuscript is pending publication by the Journal of
Public Health.

/ 21 /

Everything We Do Is About
Taking Care of People

Accreditation

Patient Feedback and
Experience Surveys

Clinical Innovations

Chapter 3
Patients

Mental Health and
Psychiatry

Clinical Training

“You have not lived today until you have done something for
someone who can never repay you.” – John Bunyan

Pharmacy

Safe, Quality Patient Care

II PATIENTS

At Wellpath, patient care comes first, and
everything we do is focused on helping the
underserved. Our clinical strategy focuses
on quality, the needs of diverse populations,
innovation for a range of uniquely
vulnerable and medically complex patients,
and addresses key challenges of chronic
diseases and behavioral health disorders.

Everything We Do Is
About Taking Care of People
Patients are our primary stakeholders. They are incarcerated or hospitalized and are
vulnerable, fragile, and often overlooked by society. They live in a jail, prison, or residential mental health facility and are neighbors who often need outpatient community
care. Whether it is a diabetic who has never been educated on the management of
their disease or the importance of monitoring their A1C level regularly, the hypertensive
who has not had access to the most basic of generic blood pressure medications, or a
patient with behavioral health disorders who has not been able to access the mental
health system, we start with an offer of help, and a path to a better and healthier life.
Ours is a true “Culture of Caring.” If there is one unifying characteristic of everyone at Wellpath, it is the deep desire to make a difference by helping our patients

/ 23 /

II PATIENTS
get well. We approach every day as a distinct honor and show up with non-judgmental compassion to provide hope and healing to those who need it most.
Treating incarcerated patients with short and long-term chronic care issues like
heart disease, cancer, diabetes, and serious mental illness is no different than treating
patients in the community, except for special considerations of delivering care in an
environment that neither the patient, their family members, or the caregivers control.
When we meet a patient in a mental health facility, we also think of family members
who want safe, compassionate, and constructive options for their loved ones. When
we encounter an individual struggling with a SUD in a WCCC, we know it is a critical
life-changing moment – a moment when they are ready for change.
We serve a diverse patient population that spans coast to coast and overseas,
and includes patients of all ages, genders, races, religions, and socio-economic
backgrounds. We care for many patients with Human Immunodeficiency Virus (HIV)
and Hepatitis C (HCV) illnesses, which, according to the World Health Organization
(WHO) are more prevalent in correctional settings than in the general population1.

Specialized Patient Care
Our approach focuses on each patient’s unique needs and SDoH. The following
are a few examples of the specialized patient care we delivered in 2021:
• COVID-19 Patients – Wellpath has implemented CDC guidelines, policies, and
procedures in different environments with different staffing levels over the past
two years. As a result, Wellpath COVID outcomes have mirrored community
outcomes, while providing care in vastly more difficult environments than
those present in the general population. In 2021, we had a 56% increase in
COVID-19 diagnoses, a 34% decrease in patient COVID-19-related mortality, and
a 41% decrease in COVID-19 related hospital admissions.2 We were an industry
leader in developing patient education materials specific to corrections, and we
partnered with National Commission on Correctional Health Care (NCCHC) to
make these materials available to others in the industry.
• SUD and MAT – Wellpath is a national leader in developing and offering MAT
services within correctional facilities. We are nationwide experts in the management of withdrawal from substances commonly abused in our patient population. We currently offer MAT programs in over 100 facilities nationwide. Our MAT
services use safe, proven, evidence-based medication therapies (methadone,

1

https://www.who.int/teams/global-hiv-hepatitis-and-stis-programmes/populations/people-in-prisons

2

Calculated using data from sites managed by our ERMA CM which includes >80% of our ADP.

In-Facility Medication-Assisted Treatment

100+

Facilities offering
some version of MAT1

32

Facilities providing
induction of
buprenorphine

350+

DEA-X Waivered
Providers

78

Facilities that continue
MAT at intake

44
1

Facilities with a
vivitrol-only program

2

Licensed OTP2 facilities
inside jails for induction of
methadone

MAT in this context is defined as the use of one, or a combination of medicines vivitrol,
buprenorphine, naltrexone, and methadone to treat opioid addiction.
2

Opioid treatment program.

buprenorphine, and naltrexone) and treatment protocols informed by the recommendation of the American Society of Addiction Medicine (ASAM).
Our staff treats individuals with co-occurring mental illness and SUDs within
our facilities. Correctional programs use evidence-based treatment approaches, including motivational interviewing, cognitive-behavioral treatment, and
relapse prevention. Our WCCCs strive to create a seamless transition to the
community for individuals with SUDs.
• Female Patients – The specialized needs of our female patients include
chronic gynecological care and postnatal care. Our team includes specialized
women’s health nurse practitioners for routine care and appropriate screenings, obstetrician physicians for oversight and complex care, pharmacists
handling medication review and education, and mental health providers to
treat depression, anxiety, and other psychiatric issues that may arise during
pregnancy. Dietitians or nutrition counselors educate patients on a healthy diet
and any metabolic issues that may arise during pregnancy. Psychological care

/ 24 /

II PATIENTS

Wellpath
treats
juvenile
patients at
more than
80 facilities
globally.

is available to all patients, and we offer postnatal psychological care as well.
Women separated from older children can also receive counseling services to
work through family changes.
• Juvenile Patients – While juveniles are a small portion of our patient population, less than 5% of our ADP, Wellpath understands the needs of young
patients who are still developing physically, intellectually, and emotionally.
Our experience working with this special population includes both ado-

lescent medical and mental healthcare essential to assessing and treating
their unique healthcare needs. The treatment team for this young population creates a therapeutic and motivating environment to help young
offenders change. Wellpath follows youth-specific NCCHC standards, policies, and procedures. We foster a therapeutic transition back into family,
school, and community by providing support and education to the youth
and their family or support team on communication, coping, life skills,
connecting with community resources, and creating a success plan.

/ 25 /

II PATIENTS

Accreditation
Wellpath currently provides healthcare services for more than 200 facilities accredited by the NCCHC, American Correctional Association (ACA), Joint Commission, or Accreditation Association for Ambulatory Health Care (AAAHC).
The Joint Commission provides accreditation and
certifies medical programs and organizations, including hospitals. The accreditation requirements for the
Joint Commission exceed the standards of both the
NCCHC and ACA.
We have 24 Triple Crown facilities among our
partners. The National Sheriffs’ Association (NSA)
presents its prestigious Triple Crown Award to correctional facilities that achieve accreditation by the NCCHC, ACA, and Commission on Accreditation for Law Enforcement Agencies (CALEA).

“During the course
of our partnership,
we have carried out
program improvements
that include firsttime accreditation
by the ACA and
implementation
of technology
resources such as
[their] ERMA and
electronic medication
administration record.”

According to the NSA, “Achieving
these accreditations individually
is a daunting task. Acquiring all
three at the same time is an extraordinary feat. The Triple Crown
distinction is so rare that since
the establishment of the award
in 1993, fewer than 100 sheriffs’
offices have qualified.”1
Wellpath has never failed to
obtain medical accreditation at
our partner sites, nor have we
ever lost accreditation.

Opioid Treatment
Program Accreditation

The SRJ in Alameda County,
California, recently renewed its
NCCHC OTP Accreditation, which
means the jail is a fully licensed
opioid treatment program inside of the jail. As a result, they can prescribe
and dispense methadone and the other forms of MAT treatment – a rare
achievement in the correctional world.

Director of Health Services
Current Wellpath Partner

24
100%
1

Local detention
Triple Crown
facilities
Success rate for
partners seeking
accreditation

https://www.sheriffs.org/about-nsa/triple-crown-award

National Committee for
Quality Assurance (NCQA) Accreditation
We are working to have our Wellpath Centers of Excellence (COEs), a service
of the Wellpath Healthcare Cloud, and disease pathways accredited by the
NCQA. This is a widely recognized, evidence-based program dedicated to
quality improvement and measurement. We seek Population Health Program
Accreditation, which focuses on evaluating the population and delivering
person-centered interventions based on individual needs. The NCQA will
evaluate Wellpath in key areas, including data integration, population assessment and segmentation, targeted interventions, provider support, and quality
improvement. We expect to have this certification in 2022.

/ 26 /

II PATIENTS

Patient Feedback and Experience Surveys

• Local Government and State and Federal – During 2021, we surveyed our
prison and jail populations for the first time and will continue to do so annually. See graphic for results from various Massachusetts DOC sites, the Humboldt
County Correctional Center, and the Clark County Correctional Center.

At Wellpath, our patients come first, and their voices matter. We survey patients to gain feedback about their care and better understand their experience while identifying our strengths and weaknesses.

» Local Government in Clark County Correctional Center, Nevada – In a survey
administered to patients in the Clark County Detention Center in Nevada, our Local Government division and clinical team measured the experiences of men and
women with chronic medical and mental health needs. The responses helped us
focus on areas where improvements could be useful.

• Recovery Solutions – Our Recovery Solutions division conducts regular
patient satisfaction surveys. We received 2,065 survey responses in 2021
regarding their experience of healthcare services.

Sample Patient Experience Survey Responses Jail
& Prison Populations from Select Locations1

N = 104
1.00

2.00

2.50

3.00

3.50

Overall, I found the treatment I received to be helpful in
managing my chronic illness.

3.83

I found the treatment I received from staff including medical
providers and nurses helpful in managing my chronic illness.

3.88

I found the educational materials provided to me helpful
and informative.

1

1.50

1 = strongly disagree, 5 = strongly agree

4.50

5.00

3.70

The treatment recommendations that myself and my
medical provider made were reasonable to adhere to.

3.85

The treatment I received helped me achieve my individual
health goals.

3.89

Overall, I am satisfied with the healthcare I have received.

3.90

 urveyed locations include various Massachusetts DOC sites, the Humboldt County Correctional Center, and the Clark
S
County Correctional Center.

4.00

/ 27 /

II PATIENTS

Clinical Innovations
Wellpath has demonstrated success in collaborating
with partners in developing innovative solutions for
their healthcare programs; for instance, our remote
telehealth service is one way to meet the special
needs of our incarcerated patient population. Combining our telehealth encounters and online specialty referral consults, our provider teams successfully
conducted 482,158 telehealth interactions in 2021.

l_'~
, .,

wellpatn
Healthcare Cloud

Wellpath Healthcare Cloud

Wellpath Healthcare Cloud improves:

The Wellpath Healthcare Cloud is a suite of
technology-enabled, remote healthcare services
and tools allowing us to deliver the appropriate
care to the most patients who can benefit from a
remote encounter, with the lowest waiting time
possible. With a simple click of a button, on-site
staff can access expert resources for treatment
planning, decision-making, referrals, and longterm care.

• Clinical quality
• Patient and staff safety
• Time to expert emergent and specialty care
• Decision-making for off-site visits
• Care standardization
• Clinical best practices and risk reduction

Correctional healthcare transformed through technology-enabled healthcare services
and tools delivering the best care, to the most patients, in the shortest amount of time.

Services

Tools and Apps

Wellpath Now
Emergent, on-demand medical and
mental healthcare telehealth services.

Wellpath Telehealth
Scheduled, non-urgent medical and
mental healthcare telehealth services.

Wellpath Connect
Care management services including
provider consults that enhance triage
and treatment decisions.

Wellpath Centers of Excellence
Chronic care management (e.g HIV, HCV)
powered by affiliated academic expertise.

Electronic Records
Management Application –
ERMA is our web-based application
specifically designed for healthcare
delivery systems in correctional facilities.

Reporting
An extensive logging system for collecting
data and statistics to analyze trends in the
utilization of health care services.

Patient Activity Monitoring
Management (PAMM)
A computer tablet and application patient
observation system that improves patient
safety while lowering risk.

Partner Portal
Provides our people and partners near real-time
reporting on statistics related to the delivery
of care, such as staffing hours provided
and off-site treatments.

/ 28 /

II PATIENTS
The Wellpath Healthcare Cloud includes:
•

•

•

~

~+~

•

W
 ellpath Now is staffed by emergency medicine providers
trained to deliver time-sensitive emergency evaluations
and consultations for emergent and urgent on-demand
telehealth services. Our Wellpath Now provider response
time averages five minutes. On-site nurses, custody staff, and
providers have immediate video-enabled access to seasoned
providers, bringing emergency department expertise directly
to our patients and enhancing our on-site care delivery
capabilities. Our client partners have significantly reduced
the cost of emergency room transfers by using Wellpath
Now, and our patients see the appropriate emergency
provider without the delay traditionally experienced in a
hospital emergency department.
Wellpath Telehealth is easy to use and powered by Wellpath
clinical expertise. This online tool provides a secure single signon (SSO) process to improve the user experience and simplify
care coordination. In addition, it enables online scheduled patient visits with various primary care and specialty services, such
as telepsychiatry. In 2021, we performed more than 184,000
telehealth visits, approximately 73% of which were synchronous.
We expect to expand this program to more partners for patient
care and operational efficiencies.
Wellpath Connect offers centralized care management and
off-site management services that enhance healthcare triage
and treatment decisions. On-site providers gain timely access to
specialty care through enhanced remote care coordination and
expert clinical consultations via eConsults. Wellpath Connect
has significantly reduced unnecessary off-site specialty consults,
reduced agency transports, and mitigated avoidable safety risks.
Overall, we conducted 297,366 online specialty referral consults
in 2021, a 145% increase from 2020. Compared to the traditional
model, Wellpath Connect services continue to exceed quality
metrics related to improved precision of clinical decision-making.

Wellpath COEs provide best practice chronic care management
(e.g., HIV, HCV) powered by academic medicine-affiliated expertise. COEs leverage telehealth to optimize best practice clinical
outcomes, implement evidence-based protocols, increase
access to subspecialty care, and achieve the highest community
standards of care for chronic conditions. Our COEs provide care
for almost 100,000 of our patients among our divisions.
We currently have COEs to treat patients with the following diseases:
» Infectious Diseases (HIV, HCV)
» Autoimmune/Inflammatory Diseases (Crohn’s, Multiple Sclerosis, Psoriasis/Psoriatic Arthritis, Rheumatoid Arthritis)
» Oncology

Wellpath Now Key Stats 2021
~

~~
-=-

titll

TOTAL WELLPATH
NOW CONSULTS:

2587

2159 acute calls
428 routine calls

PATIENTS
TREATED ON-SITE:

1388

(64% On-site
Treatment Rate)

NET PROMOTER
SCORE OF 78
“Best in class”
user experience

•

c+J~I....
_ _ _ i;;a:

·o-

o-

~

ttt

ONLY 3%

of patients are transported
to ER within 48 hours post
on-site treatment

AVERAGE
WAIT TIME:
~5 minutes

0%

MORTALITY
RATE
within 24 hours of
on-site treatment

April - December 2021

/ 29 /

II PATIENTS
• HIV COE – Our HIV COE incorporates best practice care delivery and best
available pricing for specialty pharmaceuticals in collaboration with provider
specialists from our academic medical center partner. Therapeutic optimization addresses quality and total cost of care by choosing the correct pharmacological treatments to suppress viral load and improve medication adherence.
Specifically, we can use evidence based specialty drug treatment regimens to
maximize outcomes, with HIV care performed by infectious disease experts
specializing in corrections. Outcome measures include suppressing circulating
viruses, preserving immunologic function, reducing morbidity and mortality,
and preventing transmission. These outcome measures are made possible by
optimizing screening, laboratory testing, continuity of care, and therapeutic
optimization. Our HIV COE program has achieved viral suppression rates 30%
higher than the national average. Our HIV COE has been able to:
» Improve receipt of HIV care and improve care within one month of intake for
90% of patients

» Improve retention in HIV care to greater than 87%
» Improve HIV viral suppression to greater than 92%, including 30% higher viral suppression rates than the national average by addressing the
social determinants often cited as inhibiting medication adherence for
patients with HIV: housing, food, access to care, and disease state/medication literacy
These outcomes are significantly better than the reported outcomes of CDC’s
Selected National HIV Prevention and Care Outcomes in the United States
National HIV/AIDS Strategy, 2020.
Wellpath provides confidential, case-by-case HIV testing and counseling to patients
who request it. We report confirmed cases of HIV to the local health department as
required by law.

Wellpath Outcomes as Related to Selected National HIV Prevention and Care
Outcomes in the United States National HIV/AIDS Strategy, 2020 (NHAS 2020)1
120%
100%
80%
60%
40%
20%
0%

I I I
I I I

I I

Receipt of Care

I I

I I I
I I I

I I

Retained in Care

I I

I I I
I I I

I I I
Viral Suppression

74%

58%

Wellpath 2019

100%

80%

81%

Wellpath 2020

98%

93%

90%

Wellpath 2021

98%

87%

92%

2
■ Benchmark

■
■
■

I I

1

Wellpath outcomes include 120 patients from Arkansas DOC.

2

https://www.cdc.gov/hiv/pdf/library/factsheets/cdc-hiv-national-hiv-care-outcomes.pdf

62%

/ 30 /

II PATIENTS

Mental Health and Psychiatry
Mental Health
Mental health issues are prevalent in nearly all correctional environments,
and are a key focus for Wellpath. Approximately 40% of our patients in jails
and prisons have mental illnesses. Wellpath provides behavioral health services in more than 300 facilities. Wellpath mental health assessments comply
with NCCHC standards and The Joint Commission for mental health and
recovery facilities.
Admission to a correctional facility or recovery hospital can overwhelm and
distress patients. Early establishment of a proactive plan of care begins as soon
as possible after admission. Making early contact and establishing rapport with
a mental health provider has been shown to ease patient concerns and fears by
letting them know help is available. This key relationship can establish and maintain stability throughout incarceration.

Patient-Centered Mental Healthcare
Wellpath promotes patient empowerment, independence, and self-sufficiency
as integral aspects of our recovery and treatment model. Trauma is prevalent
among patients served by the mental health and criminal justice system, and we
work with them to minimize trauma and maximize choice.
Active treatment planning and consistent care build patient trust, reduce
crises, and identify harmful trends early - all key factors in treating behavioral issues. Our patient-centered culture promotes recovery and strives to
reduce recidivism.

Evidenced-Based Programming
Our evidence-based mental health programming targets specific issues and
addresses recidivism risk factors. Programming includes patient assessment
and evaluation, suicide prevention, special needs treatment plans, referrals,
ongoing care, and discharge planning.

/ 31 /

II PATIENTS
Identification of Unstable Patients
An important patient care goal is identifying individuals with mental health
issues that may interfere with their functioning, the operation of the facility,
or both. We try to stabilize individuals who enter the facility with chronic
mental health conditions. We recommend a more intensive mental health
program if mental health issues cannot be safely addressed in the correctional setting.

Psychiatry Solutions
Wellpath values multidisciplinary and supervisory clinical collaborations that
give our local teams access to consultations and case discussions with individuals and groups with expertise in forensic psychiatry, psychology, somatic
medicine, law, and healthcare administration.
We seek out community records to confirm existing psychotropic medication
regimens to provide continuity of care from intake to release. When appropriate,
we initiate referrals for psychiatry services, special needs program enrollment,
placement in identified mental health units, and group programming –
including substance abuse treatment services.
Wellpath provides mental health or psychiatry services at over 350 partner
facilities throughout the country. In facilities where another contractor, local
agency, or group provides mental health services, we work cooperatively as the
medical services provider, engaging with the behavioral health team, to meet
this population’s needs. To support the work done by the on-site team, we have
more than 140 medical and mental health specialists available in 40 specialty
areas via Wellpath Connect in the Wellpath Healthcare Cloud.

Suicide Prevention and Awareness
The overwhelming fear and/or depression that can be brought on by incarceration sometimes leaves our patients feeling hopeless. These feelings are often
exacerbated by other factors such as receiving bad news, sentencing, and the
side effects of medically supervised drug and alcohol detoxification. Suicide as
a result of these emotional changes is thus a risk with our patient population.
We use evidence-based assessment (e.g., the Columbia Suicide Severity Rating
Scale) and treatment protocols (e.g., Collaborative Safety Planning) in our suicide
prevention program. We assess patients for risk of self-harm at intake and mon-

To save a life, all you need is…

2 EARS &
1 HEART
Listening
is the key to
suicide prevention.
Suicide prevention is everyone’s
responsibility. Don’t assume someone
else sees and hears what you do.
Take action now.

Signs of Increased
Risk for Suicide:
• Talking about dying or suicide
• Saying goodbye
• Giving away possessions
• Anger
• Hopelessness, helplessness
or desperation
• Mood changes
• Mentioning strong feelings
of guilt and shame
• Substance use or withdrawal
• Receiving bad news

If you are concerned about yourself or someone else, reach
out to a mental health or medical professional at this location.

Brought to you by the Wellpath Zero Suicide Committee.

itor them throughout incarceration or hospitalization. A Qualified Mental Health
Provider (QMHP) completes a Suicide Watch Initial Assessment and starts suicide
watch for patients at high risk of self-harm.
Our Zero Suicide Committee (ZSC) oversees ongoing suicide prevention processes and education across all Wellpath divisions. Our committee recognizes Suicide
Prevention and Awareness Month in September with speakers, resources, training,

/ 32 /

II PATIENTS
and events designed to make everyone, including our partners, a “noticer” to save
lives. Our theme for Suicide Prevention and Awareness Month in 2021 was “2 ears
and 1 heart are all you need to save a life.” We hope to prevent as many of these
unfortunate events as possible through continued education and awareness.
The committee also publishes the Helping Our Patients Every Day (H.O.P.E.)
Highlights Suicide Prevention and Awareness Newsletter. This newsletter updates our team on the organization’s suicide prevention efforts to expand and
enhance our mission to save lives. We adopted the name H.O.P.E. Highlights
to reinforce our mission to Help Our Patients Every Day. H.O.P.E. also has a
meaning for our patients to Hold On, Pain Ends.

Recovery and Re-Entry Services
Our Recovery Solutions division is a premier provider of mental health and residential treatment services, with 22 years of experience operating state forensic
and civil psychiatric hospitals and adult residential treatment centers, as well
as jail-based competency restoration programs. We have a vast knowledge of
industry-leading, effective, and empirically supported practices. We use innovative methodologies and program models to treat patients with mental health
conditions, and patients and individuals with SUD.
Forensic Treatment
Our Recovery Solutions division provides competency restoration services to
approximately 650 individuals each day and produce more than 2,100 competency reports to the courts in any given year. We collaborate with state and
county partners in California, Colorado, Florida, Massachusetts, South Carolina,
and Washington to increase our forensic capacity.

401 lives
saved with
Narcan®
2021
Since we started
using Narcan®
in 2015, our
staff saved 1,377
patients from
overdosing.

Wellpath stocks Narcan® in emergency response kits at our partner facilities as
allowed by state law. We train nurses to administer Narcan® when a patient may be
undergoing an opioid overdose. Patients found unresponsive with unknown cause,
pulseless, or apneic receive Narcan® as part of the resuscitative process.

Jail-Based Competency Treatment (JBCT)
Individuals must be competent to participate in the legal process and exercise
their rights when facing legal proceedings. Working with individuals enrolled in
our California JBCT programs, Wellpath can provide treatment to help restore
a patient’s competency, in 59 days, on average, and these patients can then
meaningfully participate in the legal proceedings concerning them.

Wellpath has helped many of our correctional partners provide Narcan® kits
to “at-risk” patients at release. We have also helped sites identify external
funding sources to support these potentially lifesaving efforts.

Saving Lives with Narcan®

Lifesaver Medal Program

Narcan®, also known as naloxone, is an important tool for Wellpath first responders
to reverse the symptoms of an opioid overdose and potentially save patient lives.

The Wellpath Lifesaver Medal Program, formed in 2021, recognizes team members and partners who have exceeded their job requirements and expectations

Wellpath empowers nurses to use Narcan® to save lives. Since we started using
Narcan® in 2015, our staff saved 1,377 patients from overdosing, 401 in 2021 alone.

/ 33 /

II PATIENTS
to save a life. We appreciate those who take heroic
actions when facing a medical or mental health
event. A review team selects individuals and groups
periodically who have taken heroic actions to save a
life. These individuals receive a medal from a company leader in a personalized ceremony. Team members can nominate their colleagues online. Inaugural
presentations are expected in 2022.

Clinical Training
Wellpath maintains clinical/academic
collaborations with community education partners,
to create clinical training opportunities that
improve patient outcomes available to a wide
variety of students. These collaborations enable
university and college students to work with a
patient population not normally encountered
in most mental health and psychiatric training
programs. The students appreciate experiencing
first-hand the intersection between individuals with
mental illness and the criminal justice system. This
clinical/academic partnership also nurtures and
develops young mental health professionals and
psychiatrists interested in correctional settings and
forensic hospitals. Wellpath has Clinical Affiliation
Agreements with many nursing schools that
allow nursing students to complete their clinical
rotations at our sites, learning about the specialty
of correctional healthcare.

SAVED

p. IFE
2021

W

E L L PATH

Wellpath offers Crisis Intervention Team (CIT) training to correctional staff on request. This 40-hour
training provides an evidence-based curriculum
on responding to and interacting with individuals
dealing with mental illness. We teach staff to pre-

/ 34 /

II PATIENTS
vent escalation of crises, thereby avoiding physical harm, emotional distress,
and minimizing the occurrence of trauma to both patients and staff. National
Institute of Corrections (NIC) data shows that CIT training typically results in a
decreased use of force and increased officer self-efficacy when responding to
patients. We offer standardized suicide prevention and mental illness training
to medical and partner staff through our ZSC.

Pharmacy
Wellpath provides pharmacy services in accordance with applicable laws, guidelines, policies and procedures, and accepted community standards. Our pharmaceutical management program includes:
• Formulary and non-formulary oversight
• Prescribing, filling, and administering medications
• Recordkeeping
• Appropriate licensure
• Prescriber authority certification management
• The secure and proper storage of medications
We are responsible for various pharmacy services which may include:
• On-time delivery with an accessible local backup pharmacy to ensure 24/7 availability
• Computerized systems for provider ordering through medication administration
• Inventory management and medication reordering
• Safe medication administration practices
• Simplified processes for emergency medication ordering and formulary exceptions
• Accurate medication order delivery
• Knowledgeable and accessible customer service available 24/7

Psychotropic Medications
Wellpath’s commitment to quality psychiatric care includes appropriate evaluation and treatment, and the use of psychotropic medications if clinically
indicated, in accordance with each patient’s needs and disease progression.

Our written policies, procedures, and clinical letters for psychiatric services,
which address treatment planning, laboratory studies, informed consent,
non-compliance, and management of various conditions, are based on
national standards, industry best practices, and ongoing epidemiological developments and trends. Our psychiatric services comply with applicable state
and federal rules.

Discharge Medications
Wellpath ensures patients are provided with a discharge plan to obtain the required medications to accommodate the transition to a community provider and
prevent a lapse in care. Before discharging patients, we train them on obtaining
and maintaining their medications. We also provide links to community resources for prescription services, such as InMedRx.

/ 35 /

II PATIENTS

Safe, Quality Patient Care
Wellpath constantly evaluates its performance and identifies ways to provide
safer care and meet evolving community standards and evidence-based protocols. We operate a comprehensive Continuous Quality Improvement (CQI)
program in support of these initiatives. This quality management process encourages team members to continuously ask: “How are we doing today?” and
“How can we do even better?”
The Wellpath chief clinical officer (CCO) and vice president of CQI lead this program to ensure systems and programs provide healthcare services and clinical
care delivery that meet or exceed our high expectations and standards. The CQI
plan includes on-site and off-site service assessments for quality, appropriateness, and continuity. Its goals are zero preventable harm and the operation
of systems and programs to help ensure that our patients receive quality, safe,
reliable, and effective healthcare services.
We conduct audits, medical chart reviews, and studies to ensure services
meet established minimum thresholds. We also monitor relevant areas for
quality improvement, including accreditations, credentialing, environmental
inspections, emergency drills, nursing, intake, medication management, special housing, and ancillary services.
We also apply the Quadruple Aim, a safety framework designed to help hospitals improve patient outcomes and the quality of care for our vulnerable populations. Our policies and procedures are based on NCCHC standards to ensure
patients receive quality, compliant healthcare. We use proven performance
monitoring techniques like our CQI program, Medical Administration Committee (MAC) oversight, and peer reviews to evaluate our healthcare programs.

adverse events, errors, and near misses, to systematically reduce the risks and
hazards associated with patient care. PSO participation focuses on a culture
of safety by design and a systems approach to improvement opportunities.
Most work product created through PSO participation is considered confidential and privileged Patient Safety Work Product, protected by the federal
statute. Wellpath values its PSO participation as a vehicle for enterprise-wide
patient safety improvement.

Quality Improvement Committee
A multidisciplinary quality improvement (QI) committee directs on-site CQI
activities. The site medical director leads the QI committee, which typically
includes the HSA, site safety coordinator, designated mental health representative(s), and appropriate site representative(s). The QI committee is responsible for monitoring activities, discussing the results, and implementing corrective actions if needed.
The committee meets regularly (monthly or quarterly) to review significant
issues and changes and discuss plans to improve processes or correct deficiencies. Activity records are confidential, and discussions, data collection,
meeting minutes, problem monitoring, peer review, and information collected from the CQI program are not duplicated for external review based
on our participation in the PSO.

High-Risk Items
Our CQI program addresses many forms of risk management, using clinical and
environmental risk tools, to identify and reduce variability and liability when
adverse events occur, including, but not limited to:

• CQI Committee Meetings

• Grievances

Patient Safety Organization

• Chart Reviews

• Mortality Reviews

Wellpath became part of a Patient Safety Organization (PSO) in 2016 as part of
our commitment to improved patient care and safety. The Patient Safety and
Quality Improvement Act of 2005 established PSOs to create a confidential,
non-punitive, and legally secure environment where clinicians and healthcare
organizations can voluntarily report, aggregate, and analyze data relating to

• Credentialing

• Peer Reviews

• Critical Clinical Event (CCE) Reviews

• Pharmacy Reports

• Emergency Drill Reviews

• Resolution Tracking

• Environmental Inspection Reports

• Utilization Management

/ 36 /

Workforce Diversity and
Inclusion (D&I)

2021 Team Member
Demographics

Talent Acquisition and
Retention

Development and
Engagement

Chapter 4

Health and Well-being

People
Team Member Safety

“Never believe that a few caring people can’t change the world.
For, indeed, that’s all who ever have.” – Margaret Mead

II PEOPLE

Providing quality patient care demands the best possible people. Our people strategy
emphasizes leadership, culture, and benefits to scale.

Our people strategy ensures:
• A diverse and inclusive team that
reflects the patient populations that
we serve
• Depth and quality of leadership
• A culture that supports and
appreciates team members
• We attract and retain highperforming talent
• Optimized human capital
investments
• Process improvements to achieve
our goals

/ 38 /

II PEOPLE

Workforce Diversity and
Inclusion (D&I)

• Engaged a nationally sought-after inclusion and
diversity speaker to address executives and managers on the importance and benefits of inclusion
and diversity in the workplace.

We are committed to sustaining an environment
free from discrimination and a place where our
people can thrive by creating a supportive, fair, and
safe culture of thought, race, color, national origin,
religion, sexual orientation, gender, and ability.
Wellpath is an organization where team members
can bring their “whole selves to
work”. They provide hope and
healing to our patients, partners,
and each other. Our competent
and diverse workforce aligns
with our culture and mission to
provide quality patient care.
In 2021, we achieved diversity
and inclusion goals, including:

I

• Announced a partnership with Morehouse School
of Medicine, the first medical school established at
a Historically Black College and University (HBCU)
to create a new life coach certificate program to
address and assist with the needs
and issues of justice-involved individuals. The courses will equip
leaders with the critical skills
needed to build positive outcomes and pathways to success.
Participants will receive a scholarship and upon completion
will earn the Pathway Forward
Coaching Certificate.
• Sponsored the KSCMHE at
Morehouse School of Medicine
to develop a series of webinars
focusing on care of incarcerated
individuals and improving mental
health, substance abuse, and health equity services to
formerly incarcerated individuals to reduce recidivism.

CElO ACT! ON~ FOR
'IYERSIIY & INClUStON

• Hired a senior manager of
inclusion and diversity to
develop, deliver, and support
programs, processes, and tools
to drive organizational inclusion and diversity
efforts.

• Engaged a nationally recognized firm to
create and facilitate Conscious Inclusion, a
comprehensive inclusion and diversity training
module, to 27 Wellpath Human Resources
Business Partners (HRBPs) tasked with creating a
module for future participants.
• Facilitated Conscious Inclusion training for more
than 90 Wellpath executives and managers at the
Annual Leadership Conference.

1

• Sponsored Women in Technology of Tennessee
to improve diversity among our technology hires.

Wellpath Signs CEO Pledge in Inclusion & Diversity™ | Wellpath (wellpathcare.com)

• Joined a coalition of over 2,000 CEOs by signing
the CEO Action for Diversity & Inclusion™1.
• Recognized Martin Luther King (MLK) Junior Day
as a company-wide holiday. It was previously an
optional holiday that employees could recognize
using a floating holiday. The change honors the
life and achievements of the civil rights leader
known for using nonviolent civil action in the
1960s to improve social equality for all.

“My objective is to nurture a
culture where all team members,
regardless of their backgrounds,
are treated fairly and feel valued
for the unique perspectives they
bring to Wellpath.”
Costin Shamble,
Wellpath Senior Manager of
Inclusion & Diversity
In 2021, Wellpath welcomed Costin Shamble,
our new Senior Manager of Inclusion & Diversity.
At Wellpath she will set out to influence and lead
cultural action plans that will increase equity,
diversity, and inclusion at Wellpath in our team
member experience, services, policies, processes, and the communities in which we serve.
Costin has extensive experience designing,
implementing, and facilitating D&I programs and
initiatives for businesses, government agencies,
higher education institutions, and non-profit
organizations. She has also consulted with HR
professionals on developing programs to attract,
engage, retain, and promote a diverse workforce.
A licensed attorney, Costin is a graduate of
Spelman College and Vanderbilt University Law
School and served as a judicial clerk in the United States Court of Appeals, Sixth Circuit.

/ 39 /

0.6%

4.7%
21.9%
American Indian/
Alaska Native

II PEOPLE

Asian

34.0%

2021 Team Member Demographics

Black/
African American
Hispanic/Latino

1

Native Hawiian/
Other Pacific Islander
None

Wellpath Workforce2: 14,265

Two or more races
White

48.5%

Gender Representation

9.0
Gender
Representation
by Position
2.7
%

%

0.1%

0.3%

1.6%
12.8%

12.4%
100%

100%

21.9%

an/

0.1%

20.4%

90%

32.6%

80%

Below 20
80%

55.3%

70%

••

can

50%

Female

n/
Islander

30 - 39
60%
40 - 49
50%
50 - 59

21.3%

79.6%

40%

40%
60+

67.4%

30%

aces

27.2%

44.7%

20%

0%

0%

Individual Contributor

Mid-level Manager

24.6%

Female

100%
2

Includes90%
U.S. full-time, part-time and PRN employees.

3

Individual contributors include professionals without management responsibilities who help support our goals and mission.

Individu

5

•

Male

100%
Mid-level managers include supervisors, managers, directors, and team members that either have direct reports
or oversee a functional department with the organization.

4

90%

5

80%

Senior Leader

4

•
As of December 31, 2021 for U.S. operations.

5

10%

3

1

30%
Unknown/
Undeclared
20%

10%

78.1%

4

20 - 29
70%

60%

Male

no

90%

Senior leaders include vice-presidents, executives, and the c-suite.

80%

/ 40 /

0.6%

12

4.7%
21.9%

II

American Indian/
Alaska Native

PEOPLE

Asian

34.0%

Black/
African American

Male

Hispanic/Latino

2021 Team Member Demographics

1

Female

Native Hawiian/
Other Pacific Islander

21.3%

None
Two or more races

2
Wellpath48.5Workforce
: 14,265
%

White

78.1%
9.0%

2.7%

Ethnic Representation
0.1%

100%

Ethnic Representation by Position

0.3%

0.6%

4.7%

100%

20.4%

90%

32.6%

80%
70%
60%

34.0%

50%

79.6%

40%

67.4%

30%
20%

48.5%
10%

••
••
••
••

90%

American Indian/
Alaska Native

80%

55.3%
Asian

70%

Black/
African American

60%

Hispanic/Latino
Native Hawiian/
Other Pacific Islander

80%

46.6%

70%

64.0%
76.7%

9.03 %
Individual Contributor

Mid-level Manager4

0.1%

Female

0.3%

60%
Male

50%

50%
Female

40%

40%

30%

Two or more races

44.7%

30%

53.4%

20%

White

20%

36.0%
23.3%

10%

Senior Leader5

Individual Contributor3

1

As of December 31, 2021 for U.S. operations.

2

Includes U.S. full-time, part-time and PRN employees.

3

Individual contributors include professionals without management responsibilities who help support our goals and mission.

90%

Mid-level Manager4

•

Non-White6

Male

100%

10%

78.1%

0%

2.7%

70%

90%

None

0%

80%

100%

21.9%

•

0%

Senior Leader5

Indiv

Below 20

White

100%
Mid-level managers include supervisors, managers, directors, and team members that either have direct reports
90%
or oversee a functional department with the organization.

4

5

Senior leaders include vice-presidents, executives, and the c-suite.

6

Non-white includes all ethnic categories except White and unknown/undeclared ("None").

80%
70%

/ 41 /

12.8%

12.4%
21.9%

4.0%

0.1%

American Indian/
Alaska Native

Below 20

Asian

20 - 29

II PEOPLE

Black/
African American

30 - 39
Male

Hispanic/Latino

2021 Team Member Demographics

1

Native Hawiian/
Other Pacific Islander

40 - 49

21.3%

Female

50 - 59
60+

None

27.2%

Two or more races

Wellpath Workforce2: 14,265

White

Unknown/
Undeclared

78.1%

Age Representation

Age Representation
by Position
24.6
%

1.6%
100%

100%

12.8%

12.4%

90%

55.3%

90%

0.1%

80%

64.0%

50%

21.3%

40%
30%

44.7%

53.4%

20%

27.2%

36.0%

••
••
••
•

70%
60%

30 - 39

Male

24.6%

40 - 49
50 - 59

40%

60+

30%

Unknown/
Undeclared

20%

Mid-level Manager4

27.8%

27.6%
25.2%
24.7%

10%

Non-White6

Senior Leader5

14.0%

11.7%
3.0%

Individual Contributor3

100%

As of December 31, 2021 for U.S. operations.

2

Includes U.S. full-time, part-time and PRN employees.

3

Individual contributors include professionals without management responsibilities who help support our goals and mission.

Mid-level Manager4

Senior Leader5

• • • • •
Below 20

White

1

80%

37.9%

24.3%

50%

0%

Individual Contributor3

90%

27.1%

20 - 29

0%

Senior Leader5

15.4%

20.5%

Below 20

23.3%

10%

4

3.9%

80%

76.7%

60%

le

2.1%

21.4%

46.6%

70%

1.6%
12.0%

20 - 29

30 - 39

40 - 49

50 - 59

60+

•

Unknown

Mid-level managers include supervisors, managers, directors, and team members that either have direct reports
or oversee a functional department with the organization.

4

5

Senior leaders include vice-presidents, executives, and the c-suite.

/ 42 /

II PEOPLE

Talent Acquisition and Retention

• Offered one-time bonuses to site leaders, such as HSAs, directors of nursing,
and RDOs, to recognize their extraordinary commitment.

Wellpath experienced significant growth in 2021 including our State and Federal division welcoming the Michigan and Georgia DOC. These new partnerships
brought 1,300 new team members to the Wellpath family.

• Reset wages for our team members to reflect “the new normal” for healthcare employment and moved staff into the top quartile for compensation
whenever possible.

Throughout the year, our Talent Acquisition team worked diligently to ensure
sufficient staffing to meet our patients’ and partners’ needs. In addition, we took
bold action to hire and retain top talent.
In 2021, Wellpath:
• Launched our F.O.C.U.S. initiative to support our hardest-hit sites that sustained significant retention losses. F.O.C.U.S. dollars increase pay differentials and
bonuses to nurses and other essential team members in these communities.
• Implemented bonuses, wage increases, and temporary differentials in
cooperation with our partners to supplement base compensation for nurses in
many of our locations.

$28.7M Dollars Invested
in Pay and Supplies
Bonuses - $9.3M

Lab Testing - $3.0M

F.O.C.U.S. Initiative - $6.8M

PPE - $4.4M
Temporary pay increases, employee
health expenses, additional PTO for
sick employees, and more - $5.2M

Talent Acquisition and Retention Techniques
Wellpath uses industry-leading talent acquisition and employee retention
techniques to recruit and retain highly qualified employees. Our initiatives
include strategic talent acquisition plans, competitive benefits programs,
opportunities for professional development, and structured onboarding
programs to educate new employees and welcome them to the Wellpath
family. Our skilled and responsive HR professionals facilitate recruitment,
development, and retention.
Our dedicated Talent Acquisition team of physician recruiters, nurse recruiters, managers, and coordinators source high-potential candidates, screen
applicants, and conduct interviews, using competency-based behavioral
interview questions and insights from clinical and operational specialists.
Wellpath performs primary source verification of credentials and licensure
concurrently during the interviewing and screening process. We then select
the best candidates based on qualifications, credentials, experience, references, interview results, and other objective data points.
Most healthcare professionals choose to join the Wellpath family to:
• Make a difference – For those whose calling is to serve others, this is their
moment—not only to advance their career, but also to join a mission that
aligns with their own.
• Work at the top of their license – Our healthcare professionals blend the
work of general practitioners and specialists. They become experts in treating
chronic and acute conditions of all acuity levels and must use critical thinking
and decisive action to address unpredictable and unique challenges every day.
• Seize opportunities for growth – Wellpath offers several great ways to take
their next career step while making a profound difference in the lives of an underserved patient population. At Wellpath, you can do well while you do good.

/ 43 /

II PEOPLE
• Be recognized and appreciated for their work – Those with experience in
both traditional environments and in our facilities know there is a special admiration for our people. There is a unique light in our patients' eyes. Our people
do life-changing work and we strive to support them in every way we can.

• Incumbent Recruiting – When we bring on a new partner we strive to retain existing, or incumbent, team members to stay on and join our team. We carefully vet
all professionals to ensure they meet our clinical standards and are a cultural fit.

National Recruiting and Sourcing Tools
Wellpath recruiters are vigilant in their search strategies for talent. We keep
our pipeline full by using effective tools to identify and communicate with
candidates. We use strategic media partnerships to evaluate and rotate
our posting needs daily. A few of those partnerships include TextRecruit,
AppFeeder, Indeed, and Connect, a Contact Relationship Management
(CRM) program for engaging passive talent.
Wellpath shares job postings and information across dozens of recruiting
databases and job sites through a single source. Our strategic use of various
databases ensures a continuous feed of the newest resumes and candidates
into an applicant tracking system our recruiters use to find the best candidates
in the shortest amount of time.
We invest in technology to promote our open positions and provide industry-leading people analytics. This helps us understand the growing needs in
staffing and the outcomes of our efforts. Our Talent Acquisition team has a full
candidate marketing plan using a multitude of resources, including:
• Indeed, Glassdoor, LinkedIn, Facebook, and Instagram
• Digital advertising on Google and YouTube
• Google Remarketing and YouTube campaigns
• Hiring Events and Targeted Ads
• Text, web-based landing pages, and internet radio advertising

Innovative Talent Acquisition Strategies
We identify and recruit talented staff to provide compassionate, quality care
to our patients; however, the pandemic, nursing shortages, wage challenges,
and impacts of the Great Resignation have pressured recruitment and retention. We implemented creative strategies to attract the nurses and providers
we need as part of our teams to deliver quality patient care.

773
incumbent team members
retained from new contracts
in 2021 (more than five
times that of 2020)

1,024
promotions at
Wellpath during
2021

• Internal Recruiting – We develop leaders and encourage professional growth.
We encourage team members to continue their training and development by
providing growth opportunities and posting job openings internally.
• Travel Nurse Program – Wellpath uses flexible strategies to address the current labor shortage and expand our talent search. Wellpath has 20 travel nurses
across the country. Dedicated travel nursing recruiters seek talent willing and
able to travel and work in specific regions. These nurses receive competitive
compensation with flexible contract terms of four weeks or longer.
• PRN Agreement Pilot – In 2021, we piloted and enhanced the PRN program to
improve staff availability and increase compensation for nurses who increased
their commitment. In December 2021, 23 PRN nurses joined the program. We
scheduled 96 shifts from this program.
• Academic Affiliations – A key part of our recruitment plan includes partnering with local colleges and universities, including the Morehouse School
of Medicine (an HBCU), Mercer University, Emory University, and the Augusta University Physician Assistant School to attract healthcare professionals

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II PEOPLE
for a career at Wellpath. We have implemented nurse residency programs
at partner facilities and established provider-level residency programs for
physicians, psychiatrists, and dentists. Today we have more than 100 clinical
affiliations with nursing schools and more than 50 psychiatric and behavioral
health schools. Wellpath leaders regularly engage with academic institutions.
Many serve as faculty at the Morehouse School of Medicine, Mercer
Wellpath initiated
University, the Medical University of
a master’s degree
South Carolina, Florida International
in justice-served
University, the University of Maryland,
healthcare program at
Boston University, Simmons College,
the Morehouse School
and Vanderbilt University.

77.8%
retention of team members
with over one year of tenure

of Medicine to develop

• Veterans – We seek veterans and
talent for these specific
their unique skills to succeed at
environments.
Wellpath. They have strong leadership and technical skills and perform
well under pressure. Veterans respect policies, procedures, and hierarchies,
and value integrity and commitment. Last year, 416 Wellpath team members
self-identified as veterans.
• Student Externships – Wellpath supports internships, practicums, and clinical
rotations for various clinical disciplines. By offering training experiences to students interested in serving their communities, we have attracted, and invested
in our interns to become valuable team members after graduation. We have
had notable success motivating and supervising new graduates to licensure. By
building interest in Wellpath in the community, we can recruit healthcare providers who may have otherwise overlooked this rewarding career option.
• Mental Health Professionals – We provide opportunities for mental health
professionals with provisional licenses to obtain their required supervised work
experiences working under experienced Wellpath providers at our sites.

Culture and Retention
One of our ESG goals in 2021 was to lower turnover, reduce replacement costs,
enhance training, and strengthen team spirit. We have launched a pilot program
in our local government division to help achieve this goal, using the Team Member Employee Ambassador Methodology (TEA). The program emphasizes a more
personalized and experiential onboarding process and a retention component
that reminds new team members that they are part of an extraordinary team.

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II PEOPLE

Development and Engagement
Wellpath continues to develop tomorrow’s leaders. Our dedicated Wellpath
Learning and Organizational Development (L&OD) department offers training
programs, continuing education, clinical exposure, promotion preparation, succession planning, and peer reviews.
When we identify team members with the potential to serve in future roles, we
balance formal training activities with experiential-based assignments, including
formalized programs designed to develop talent specific to our needs.
We are attentive to the development and professional satisfaction of our team
members. This dedication helps:
• Strengthen team spirit through
mutual respect
• Recognize individual
contributions
• Improve how we provide patient care and services in our
communities
• Reduce turnover and costs of
replacement and training

Judy Baiza, Nurse Recruiter
Wellpath YouTube Channel

Our 2021 L&OD activities, programs, and tools included:
• RDO Development – In 2021, 25 RDOs in our Local Government division
completed a six-month development program focused on strategic thinking,
planning, and talent development. It also included a 360° assessment and
workshop based on the book "The Leadership Challenge" by Kouzes and
Posner. Several participants were recognized for their leadership skills and
moved to larger regions. One became a regional vice president, and another
was named Local Government Leader of the Year.
• LEAD for Managers – Wellpath started a pilot program in 2021 called LEAD
for Managers. Thirty leaders participated from throughout our organization.
This program is based on an award-winning and proven content platform
to deliver a personalized experience for each leader to assess and build on

their strengths and challenges.
Leaders take a self-assessment
and are subsequently provided
with online learning recommendations. Participants can expand
their knowledge, skills, and abilities in common management
and leadership challenges such
as coaching, delegating, engagement, managing performance,
conflict resolution, and more.
In addition to the self-paced
learning, leaders participated in
a virtual workshop, “Leadership
is Everyone’s Business,” based
on the book "The Leadership
Challenge".

Vicki Smith
Local Government Leader of the Year

• Performance Evaluation – Performance management defines work, sets
expectations, exchanges feedback, and evaluates outcomes. Our annual
performance evaluation program for leaders includes Specific, Measurable,
Achievable, Relevant, and Time-Bound (SMART) goals aligned with company
objectives. Our program also reflects the Wellpath 5Hs: Humility, Honesty,
Hunger, Hard Work, and Humor. We encourage quarterly conversations on
how work is being completed and progress on our goals.
• Wellpath Academy – Wellpath offers role-specific and compliance-based online training programs and services. We offer emerging and incumbent leader
programs such as “New Leader Orientation” and the “Leadership Challenge”.
• Onboarding and Development Program – The Wellpath onboarding and
development programs include basic skills training for current and aspiring
managers. Our programs provide the knowledge, skill, and confidence to
deliver quality patient care in our unique environments. New team members participate in multi-day local orientations, and access cultural and
role-specific onboarding through Wellpath Academy.
• UpToDate® – Wellpath utilizes this clinical decision support tool and learning
system for evolving medicine. UpToDate® keeps staff current on changes in
medicine and information about drug interactions.

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II PEOPLE
• Nurse Education – Wellpath develops and delivers nursing education through various
training initiatives, including Certified Nurse Educators (CNE) independent/self-study,
formal clinical education, webinars and conference calls, and corrections-specific videos. Nurses also have access to professional nursing protocols (PNPs) and Lippincott®
for comprehensive, evidence-based, step-by-step instructions to over 1,800 procedures and skills from novice to expert covering a variety of nursing specialties.

American Nurses Credentialing Center
(ANCC) Accreditation
The Wellpath Nursing Education Unit is accredited as a Nursing Continuing
Professional Development (NCPD) provider by the ANCC Commission on
Accreditation. Accredited organizations use evidence-based criteria to plan,
implement, and evaluate the highest quality NCPD, which improves nursing
practices and patient outcomes. Nurses can apply their Wellpath Nursing Education Unit training to meet certification or licensure requirements.

BrainFood: Snacks and Facts Series
In 2021, our mental health leaders created a new webinar series to improve patient care, nourish curiosity, promote community, and enhance professional and
personal growth. Each month there is a mental health professional interview
and a presentation on a specific mental health topic.

“check-in” with team members and ensure we consider their opinions, satisfaction, and concerns. A cross-functional team of Wellpath experts develops
and executes these surveys to ensure they accurately capture and access
team member satisfaction and feedback.

Topics have included:

We conduct surveys at critical moments in the team member lifecycle. In 2021,
we revised our exit survey and rolled out progressive lifecycle (30-day, 60-day,
90-day, and 6-month) surveys gathering focused data on training, culture, engagement, recognition, and manager effectiveness. Survey feedback and data
help create action plans and company-wide initiatives that achieve the right
behavioral and business outcomes to improve Wellpath.

• Jail-Based Competency Restoration
• Social Resiliency Model
• SDoH
• Trauma
• Mindfulness Training

Wellpath Listens and Learns from Surveys
Taking care of our team members starts with knowing what matters most to them.
Healthy communication is two-way, and we listen to everyone's ideas at Wellpath.
We use surveys and focus groups to help us connect, engage, and listen.
Under the branding of Wellpath Listens, our onboarding, annual engagement,
pulse, and topic-related (e.g., pandemic and social equity) surveys periodically

Team Member Engagement Survey
The 2021 engagement survey used the “Essentials
of High-Performance” model to focus on engagement, leadership, and equip factors. We correlated
each survey item against the employee engagement index using the Priority Analysis Methodology for key drivers of engagement to ensure our
team members feel connected with our vision.

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II PEOPLE
In the 2021 survey, we increased participation by 25% and used benchmarks from
hundreds of other healthcare companies1. Relative to the benchmarks, Wellpath is
five points above on appropriate recognition. In summary, we learned:
The highest scoring survey items were:
• Team member satisfaction with Wellpath as a place to work
• Training to do jobs effectively
• Their job makes good use of their talents, skills, and abilities
• Team members have the materials, equipment, technology, etc., to be effective
Survey results indicate Wellpath Team Members feel:
• They are treated with dignity and respect
• They have the right training and access to resources
• They are more satisfied with our efforts to maintain a safe and secure work
environment
• The company has an increased focus on inclusion (up 5% from 2020)

Recognition
At Wellpath, we take the time to spotlight team member contributions to patients
and communities. Throughout the year, we shine a light on the great work done
by our healthcare heroes. Wellpath 2021 Recognition Moments included:

• Nurses Week
• Mental Health Professionals Week
• Years of Service Awards
• 5H Awards that celebrate our
core values
• Above and Beyond Award
In 2021, we partnered with John’s
Crazy Socks to provide Mental Health Professional Week gifts. John’s Crazy Socks
is a father-son venture inspired by co-founder John Lee Cronin, a young man
with Down Syndrome. John’s affinity for "crazy" socks (colorful prints and paterns) paired with his love of making people smile drive the company’s mission to
spread happiness and demonstrate what people with intellectual disabilities can
do. As well as being a successful entrepreneur, John has been an active member
of the Special Olympics his entire life. John’s Crazy Socks proudly contributes 5%
of its annual revenue to the Special Olympics.

1

Benchmark established by Worforce Sciences Associates

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II PEOPLE

Health and Well-being
Our industry-competitive Total Rewards program supports team members’ financial,
physical, and emotional well-being. We offer various company-sponsored and voluntary health benefits, discounts, and career development tools to support an array of
member needs. We evaluate our programs annually and welcome thoughtful changes.
• Compensation – We compensate team members fairly for their contributions.
Team members put patients first on the frontlines of healthcare every day. Our
responsibility is to ensure competitive wages to continue attracting and retaining team members. Our nurses are, on average, paid above the market median.
• Minimum Wage – Wellpath currently pays a minimum wage of $12.62 an
hour, greater than that paid in 44 states and 74% greater than the federal

minimum wage. We plan to increase that amount to $13 an hour in 2022
and $15 an hour by 2024.
• Health Benefits – We provide competitive benefits at affordable rates, covering approximately 73% of overall employee health costs, and subsidize a
larger portion of the healthcare cost for staff with lower incomes. We offer
a health savings account option that allows employees to make pre-tax
contributions to pay for doctor’s visits and other medical expenses. In 2021,
we also launched a unique benefit to support our team members and their
families diagnosed with cancer to assist with all stages of the process from
finding providers to managing billing and claims.
• Wellness – Through the Wellness Café, professionals across the company
offer short, weekly guided wellness activities like meditation, mental activity,
or physical exercise to encourage self-care and overall wellness.

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II PEOPLE
Support Programs
Our support programs cater to both the economic and educational needs of our
team members.
• Dare2Care Employee Assistance Fund – Dare2Care is our assistance fund
for team members who need help. Established in 2010, the fund helps
colleagues facing economic hardship in certain unexpected circumstances.
Caring for our patients and each other is at the heart of what we do. Wellpath
team members and partners can contribute to the fund one time or pledge
biweekly donations through payroll deduction. In 2021, 259 employees
received $202,000.

Dare2Care
Since inception
there have been
1,249 disbursements
totaling $1.5 million
dollars.

• T
 uition Assistance and Scholarships –
Wellpath offers full-time team members the opportunity for financial
assistance for job-related coursework
completed in pursuit of a degree or
diploma from an accredited college,
university, or higher education institution, after six months of employment. Wellpath reimburses up to
$2,000 in a rolling 12-month period.
In 2021, we paid $248,000 in tuition
assistance.
• W
 ellpath Scholarship Program –
The Wellpath Scholarship Program
strives to impact our team members
and their families by helping deserving students afford higher education.
This program awards seven $2,500
scholarships, or $17,500 annually, to
children of Wellpath team members.
We have awarded 59 scholarships
worth $147,500 since inception.

on “Patients, not Paperwork.” For example, our Concierge Services allow site
leaders to spend less time scheduling and doing paperwork, and more time providing leadership to their healthcare team.
In 2022, we plan to implement an integrated Human Capital Management (HCM)
system to provide access to what team members and leaders need – benefits,
time scheduling, etc. – without going through HR for every detail. This system
will coordinate staffing coverage in real-time, streamline management work for
leaders, and provide analytics to help leaders build better programs to engage
and develop their teams.

Introducing Concierge Services

Wellpath Leadership Advisory Council

Another way we help people is through a centralized support team and Concierge Services center so that our site leaders and healthcare professionals focus

The Leadership Advisory Council is a standing committee that ensures a strong
connection between the field and home office relative to new initiatives and

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II PEOPLE
changes to existing policies, processes, and procedures. The council limits its
activities to advising on matters that directly concern managers and team members in operations. The council gives advice and recommendations to sponsors
and owners of initiatives, processes, and procedures.
The purpose of this advisory council is to:
• Obtain input and perspectives from the field during the design phase of
initiatives, processes, and procedures to help ensure they will work as
intended.

Benefits of the Nurse Advisory Council include:
• Improved communication from the field during the design phase of initiatives,
processes, and procedures to help ensure they will work as intended.
• Enhanced change management and ownership for successful implementation
and sustainability.
• Reduced turnover and improved employee engagement and satisfaction.

Wellpath Nurse Preceptor Program
In 2021, Wellpath launched a new Nurse Preceptor Program. This program is one of the ways
Wellpath promotes the availability and quality
of nursing careers. It recognizes the challenges
of correctional medicine and provides unique
training and mentorship for new nurses to provide
innovative patient care. It also gives nurses a pathway to leadership and career development.

• Provide a feedback loop mechanism between the field and home office.
• Eliminate the need for each project to create its own advisory group.
• Seek guidance to inform change management plans to help ensure adoption
and realize benefits.
• Gain buy-in for initiatives early in their development.
• Provide feedback on the effectiveness of programs, policies and processes, and
on the support provided by the home office.
The Leadership Advisory Council:
• Includes high-performing and emerging front-line and second-level leaders
representing the different divisions.
• Provides sponsors and owners with objective information and opinions about
the organization.
• Provides input, knowledge, and context about field needs related to the initiative, process, and procedure being discussed.
• Serve as champions for the initiatives, processes, and procedures.

Wellpath Nurse Advisory Council
The Wellpath Nurse Advisory Council is composed of 12 nurses from 12
different sites across all divisions. It utilizes a shared governance decision
making model which empowers our team to contribute to the nursing practices and positively influence the work environment for our nursing team
members.

Our inaugural class of nurse preceptors will graduate in mid-2022. We will expand
this program to provide comprehensive training of preceptors across the organization. Selected preceptors participate in e-learning and in-person training to develop
the knowledge, skills, and practices to build an industry-leading nursing workforce.
The Wellpath clinical nursing leadership team has developed our comprehensive
preceptor program. Graduates of the program receive a handbook that highlights
valuable information, including:
• The Wellpath Way (our mission, vision, and values)
• The roles and responsibilities of a preceptor
• Preceptor training policies
• Preceptor training experience
• Tools to guide the effectiveness of preceptors
Preceptors have access to Lippincott, a best-in-class web-based resource to access
policies, practices, and clinical information necessary to ensure clinical excellence.

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Team Member Safety
We provide a safe and healthy environment for medical and correctional staff
and patients. Employees receive regular training aimed at promoting personal
safety and well-being. Security is an essential part of risk management in the
correctional environment. We train new employees and subcontractors on safety
and security in a correctional setting.

We work with insurance carriers to create a national benchmark for correctional
healthcare. To promote a process of evaluation, improvement, and safety, we
track key metrics, including:
• TRIR
• DART rate
• LTIR
• Work-related injury fatalities

Our Injury and Illness Prevention Program addresses:

• High consequence injuries

• Responsibility

• Locations with no injuries

• Compliance

Each team member has a role in preventing workplace injuries and illnesses
by understanding and complying with the safety program requirements. Team
members can report safety hazards without fear of retribution. No job is so important – or any service so urgent – that we cannot take time to work safely.

• Communications
• Hazard assessment
• Accident/exposure investigation
• Hazard correction

A location-specific safety committee meets monthly to review inspection and
accident investigation results, and discuss hazards and exposures. Each committee makes recommendations to management for preventing future incidents.

• Ongoing training
• Recordkeeping

2021 Health and Safety Key Metrics1

1
2

2021 Safety Training1,2

Correctional
Institutions (State
Government)2

Nursing and Residential
Care Facilities
(State Government)2

Wellpath

Total recordable
incident rate (TRIR)

9.2

13.7

4.4

Days away, restricted, or
transferred (DART) rate

6.4

9.7

1.7

Lost Time
Incident Rate (LTIR)

6.0

8.5

1.0

Data for additional health and safety metrics can be found in Chapter 8.
 .S. Bureau of Labor Statics, 2020 Benchmarks. The North American Industry Classification System (NAICS) codes
U
presented are: 623 – Nursing and residential care services and 92214 – Correction institutions.

Number of safety courses completed3

53,397

Number of safety training hours completed4

23,365

1

 ourses include the following topics OSHA-related topics: Active Shooter, Hazard Communications, Bloodborne PathoC
gens, Emergency and Disaster Preparedness, Security Awareness, Infection Prevention and Control, Injury and Illness
Prevention, and Violence Prevention in Healthcare.

2

The number of safety courses completed and corresponding number of safety training hours for 2020 have been updated from the
values reported in the 2020 ESG Report due to a historical records review. Updated values can be found in the Performance section.

3

 umber of courses completed by active employees during the reporting year. Training year is from March 1st through
N
February 28th.

4

Number of hours for completed course are per estimated completion time.

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Successful Partnerships

Partner Retention

Industry Partnerships

Operational
Improvements

Chapter 5
Partners

We Are Proud Healthcare
“Fixers”

Consultation Services

“Relationships are based on four principles: respect,
understanding, acceptance, and appreciation.”
– Mahatma Ghandi

Philanthropic Efforts

Case Study

II PARTNERS

Our strategy to help the most people requires
exceptional partnerships. We do not typically
use the words “customers” and “clients.”
Success requires an ever-growing family of
partners with a shared vision to help people
and make a difference in our communities.
Successful Partnerships
Wellpath typically provides patient care in facilities operated by our partners. We
must collaborate, cooperate, and work seamlessly with them to ensure effective
and efficient care of our shared patients.

Wellpath retained
approximately 95%
of our existing
partner agency
revenue in 2021.

“Wellpath’s
commitment to
providing the
best possible
care and their
responsiveness in
doing so makes
this an extremely
successful
partnership.”
Rory Griffin, Deputy
Director, Arkansas DOC

Our Mantra is “Always Do The Right Thing.” This mantra is more than an aspirational company tagline; it was assigned to us by one of our long-term partners,
who stated: “What I appreciate most about working with you is I can count on
you to always do the right thing.”
This mantra is about excellence in everything we do – from the exam room to
the corporate boardroom. Our patients, people, and partners work together to
provide excellent care to a fragile patient population.

Partner Retention
Wellpath patient care excellence is represented in our partner retention. At
Wellpath, our partner satisfaction and retention are exemplary. On average,
we retain approximately 95% of our existing partner agency revenue year
over year. Our partners stay with us and often ask us to enhance and expand
our services because we provide quality care. In 2021, we added new staff or
services in 57 partner agencies.

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II PARTNERS
Net Promoter Score (NPS)
Surveys – We continually
measure partner satisfaction
with tools like NPS, which
is used by thousands of
companies worldwide, including
two-thirds of the Fortune 1000
companies. NPS measures
partner satisfaction from a
much higher bar: “How likely,
on a 0-10 scale, would you be
to recommend Wellpath to a
colleague?” (the “NPS Question”).

In 2021, our
average Net
Promoter
Score was
49.90 based
on 960
recorded
scores.

What
a good
NPS?
What
is aisgood
NPS
score?
GOOD

NEEDS IMPROVEMENT

-100

0

GREAT

EXCELLENT

100

Wellpath seeks feedback from
multiple partners during on-site
visits and through surveys. We
train our team members to ask
this important question: “If you
didn’t give us a 9 or 10, what do
we need to get there?” We do
not avoid critical partner input;
instead, we identify opportunities
to improve our services. We want
every person at every partner
site to be a Wellpath promoter.
We reflect, analyze, and react
to ensure awareness of the
strengths and opportunities we
should act on after listening to
our partners. NPS results range
from +100 (100% promoters) to
-100 (100% detractors). The most
admired companies in the world
generally achieve scores in the
50s, 60s, or 70s.

Wellpath tracks rolling NPS results quarterly. By including NPS in the fiber
of our partner relationships, we expect to improve our underlying partner
satisfaction by identifying and resolving issues before they can become
significant problems.

Industry Partnerships
Wellpath has strong connections with industry-leading associations like NCCHC,
ACA, ANCC, and National Alliance on Mental Illness (NAMI). We have helped the
NCCHC develop standards, accreditation surveys, and training for lead surveyors. Typically, more than 50 Wellpath team members attend the annual NCCHC
conference for training or as presenters and educational session leaders.
Wellpath is the only correctional healthcare organization accredited by the ANCC to
ensure excellence in NCPD. The Wellpath Nursing Education Unit passed a systematic, comprehensive peer review, met the ANCC standards, and was confirmed by the
Commission on Accreditation.
Our chief nursing officer (CNO), Heather Norman, serves on the Board of Directors for
the American Correctional Nurses Association (ACNA), and also serves as the Chair
for their Special Projects Committee.

Heather E.
Norman
Wellpath Chief
Nursing Officer MSN,
RN, MBA, NE-BC, CNL

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II PARTNERS

Operational Improvements
We constantly look for ways to enhance our clinical and operational efforts. From
technological innovations to enhanced site support, we strive to help as many
people as possible.

for shared communication. Site data, such as care delivery, staffing hours, intakes,
health assessments, and medication passes are available online for review and
comment by our partners. Those comments help us make operational adjustments going forward to help meet our partners’ needs, as those needs change.

Enhanced Site Support

Technological Innovations

ACE Team

Wellpath Healthcare Cloud – Our innovative technology solution, the Wellpath
Healthcare Cloud, which is composed of Wellpath Connect, Wellpath Telehealth,
Wellpath Now, and the Wellpath COEs, helps us to provide the services our patients need in the most efficient and effective way possible. The COEs focus on
HIV, HCV, oncology, and autoimmune diseases. In 2021, we developed COEs to
support the following:

• Create operating procedures, site-specific programs, and CQI toolkits

• 25 Arkansas DOC and Community Correction sites
• 6 Maine DOC sites
• 60 Georgia DOC sites
• 29 Michigan DOC sites
• 7 local government sites
• South Carolina Department of Mental Health Program
Partner Portal – Partner communication and transparency are key for a successful,
long-term relationship. Our Partner Portal is a confidential, secure digital gateway

The ACE Team, which stands for Achieving Clinical Excellence, provides clinic support
and implements new contract requirements. The ACE team members:

• Monitor risk factors
• Mentor site leaders
• Share best practices
• Assist with root-cause analyses and corrective action plans
• Monitor key performance indicators (KPIs) to identify trends, accreditation
tracking, and more

Wellpath Warriors
Wellpath Warriors are carefully selected and trained teams serving as Wellpath
care and culture ambassadors. They assist with contract start-ups across the
country and help implement crucial systems and processes to transition new
Wellpath sites. Training includes:
• Administration
• Policies and procedures
• Receiving screening
• Health assessment – Clinical Institute Withdrawal Assessment (CIWA)/Computers on Wheels (COWs)
• Appropriate use of Safety Cell
• Pregnancy
• Suicide prevention emergency response
• Medication administration and bridging
• Sick call

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II PARTNERS

We Are Proud Healthcare “Fixers”
It is common for new partners to ask for help improving or revamping a broken healthcare program. Wellpath collaborates with new partners to redesign
and establish new and improved healthcare programs that deliver quality
care. We are known for turning programs around, a key reason we have experienced steady growth.

The “Turn Around” in
Milwaukee County
When Wellpath took over operation of the Milwaukee
County healthcare program, the facility had been under
a consent decree since 2001. The previous provider was
not meeting the client’s expectations or the patients’
needs. There had not been a psychiatrist on-site for more
than a year and more than 60% of their staff were agency
nurses. We started recruiting immediately upon transition
and focused on onboarding for all the new staff we added. In our first year, we reduced the vacancy rate from
more than 60% at contract start to less than 3%. Our site
leadership worked to increase morale to foster a culture
of caring and acceptance, forming a “Milwaukee Strong”
employee committee to engage team members and
reward their hard work. In May 2021, the Jail’s medical
program received NCCHC accreditation.

“As Milwaukee County Sheriff, I am committed
to ensuring that everyone entrusted to our care is
treated with dignity and respect and receives the
best medical services available. Today’s achievement
recognizes that the dedicated correctional
professionals of the Milwaukee County Sheriff’s Office
have spared no effort in transforming the Milwaukee
County Jail into a facility that recognizes the dignity
and worth of everyone, and it stands as testament
to the exemplary performance and partnership with
Milwaukee County’s health care provider, Wellpath.”
Earnell R. Lucas
Milwaukee County Sheriff

Dr. Enid Trotman, our
Milwaukee County Medical
Director, was awarded with
our Physician of the Year
award in 2021.

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II PARTNERS

Consultation Services
Our consultation services review existing
programs and advise on aspects of the healthcare
delivery system. Services include evaluations and
recommendations for new programs or architectural
plans, staffing patterns for new facilities, alternate
pharmaceutical, and other systems.
Wellpath is known for implementing innovative operational and clinical initiatives and providing partners
with effective strategic planning services based on
our experience. Our corporate management team,
has accumulated years of experience developing and
operating healthcare units in facilities at the federal,
state, county, and municipal level.

New Medical Facilities
Should a partner decide to build a new facility or expand
existing space, we can recommend staffing and offer
consultation services regarding the design of the medical area(s). This can increase efficiency for healthcare
and correctional staff operations, resulting in additional
cost savings for our partner. Wellpath will assign a designated liaison to attend relevant meetings about future
facility renovations or construction and the subsequent
transition of services. We have historically collaborated in designing new medical facilities in Mecklenburg
County, North Carolina; Davidson and Shelby Counties
in Tennessee; Orleans Parish, Louisiana; and Will and
McHenry Counties in Illinois. Wellpath Recovery Solutions designed the buildings for the Columbia Regional
Care Center and Treasure Coast Forensic Treatment
Center. We designed, built, and operate the South Florida
State Hospital, Montgomery County Mental Health Treatment Facility, South Florida Evaluation & Treatment Center, Florida Civil Commitment Center, and South Carolina
Civil Commitment Center.

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II PARTNERS

Philanthropic Efforts
Our partnerships go beyond the walls of the facilities in which our dedicated
caregivers work. On any given day, in cities and towns across the country, our
team members can be found in the community volunteering their time to those
in need, including children, the homeless, and the elderly. We have developed
a true culture of caring that extends deep into the communities we serve. The
people in our facilities are active members of their communities.
• In Merced County, California, our team participated in the annual toy drive
and the Run for the Fallen, honoring peace officers. Wellpath sponsored a veteran for the Central Valley Honor Flight program through an annual Veterans
Garage Sale and provided meals at the D Street Homeless Shelter. We also
supported the Merced County Operation Christmas Star event by giving gifts
to 815 families, including 2,674 children.
• In Oakland County, Michigan, our clinical staff working in the sheriff’s department
hosted a holiday collection to benefit a local organization. This year, we hosted a
book drive for an early intervention outreach program, Oakland Family Services.
Wellpath proudly sponsored the Frank Knasiak Memorial Golf Outing, to support a
variety of community groups such as food banks and domestic violence shelters.
We also worked with the Oakland County Animal Shelter.
• In Key West, Florida, Wellpath team members participated in the Thanksgiving Back to Key West Fundraiser, with all proceeds benefitting the Keys
Learning Center and Michelle’s Foundation. Michelle’s Foundation was established in honor of Michelle Keevan Halpern to help children achieve their
highest potential. Keys Learning Center helps students with test preparation,
credits, math, reading, behavior, or other issues causing educational advancement.
• In Richmond, South Carolina, Wellpath team members participated in the Central Savannah River Area (CSRA) Heart Walk. We also supported the American
Heart Association Women of Impact Campaign to place two cardiopulmonary
resuscitation (CPR) kits at local High Schools.
• In New Orleans, Louisiana, our team members donated time to an annual
health fair, donated to the Battered Women’s Shelter, spearheaded an annual
Christmas Toy Drive, volunteered for the medical stops at the annual Zulu Run/
Walk, and volunteered at the annual local Easter Egg Hunt.

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II PARTNERS

Randi Uebelhor, Registered Nurse
Wellpath YouTube Channel

Case Study
Partnership with Norton Healthcare – Kentucky DOC Oncology Program
Wellpath identified unusually high rates of cancer diagnoses and treatments among patients
incarcerated within the 12 facilities across the state. Wellpath partnered with Norton Healthcare, a local
oncology team, and has an on-site chemotherapy-certified advanced registered nurse practitioner
(ARNP) to establish a total oncology care program.
This program provides patients with a treatment plan developed by the oncology team and with access to
on-site chemotherapy at the Kentucky State Reformatory (KSR). In 2021, 48 patients were treated through
this program. Oncology services include infused chemotherapy and immunotherapy, injections, oral
chemotherapy medications, and radiation therapy.

2021 Key
Figures
•

75% remission rate

•

48 patients treated

•

102 telehealth sessions

•

457 on-site patient
encounters

•

493 off-site patient
encounters

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Corporate Governance

Corporate Compliance
Program

Ethical Business Practices

Privacy and Data Security

Procurement

Chapter 6
Process
“Integrity is doing the right thing, even if nobody is watching.”
– Jim Stovall

II PROCESS

Corporate Governance
Our corporate governance
policies protect and promote
integrity by communicating
clear guidelines to train and
educate team members
regarding compliance and
good business practices.
Corporate governance is our foundation for
ethical behavior and integrity. Wellpath reduces
risk while improving effectiveness, security, and
compliance utilizing an approach that integrates
ethics and compliance into our daily operations.
Our policies, procedures, and other governing
documents create a system that encourages
transparency, accountability, fairness, and trust in
our business operations. The Board reviews and
approves our corporate governance practices to
align with our business strategies, social responsibilities, cultural and financial goals, and stakeholders’ best interests.

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II PROCESS
The Board
Our independent and diverse Board helps consider
the various stakeholders, including our patients
and partners. Our business and affairs are overseen
by The Board, with nine members; three are independent. Four Board members represent women
or minority constituencies. Two are practicing
physicians, and one is a former member of Congress and a vocal advocate for improved access to
behavioral healthcare in the U.S. Our CEO and our
president are the only members of The Board who
are Wellpath employees.
The majority shareholder of Wellpath elects Board
members who serve until voluntary resignation or
removal by the majority shareholder.

The Board’s
Composition
Women

22%

Black/African American

11%

Hispanic/Latino

11%

Asian

11%

Independent Individuals

33%

Combined Professional
Experience

261 Years

The Board meets quarterly. Designated committees
provide specific guidance and oversight to defined
segments of Wellpath’s operations/business. They
include the Compensation Committee, Legal and
Risk Committee, Compliance Committee, Audit
Committee, and Partnership Committee. Board
members elect officers and set the strategic direction for the Company’s management team.

Executive Team
The Wellpath executive team executes a strategic
plan adopted by The Board and oversees day-to-day
operations. The executive team is led by and includes
the CEO, president, chief financial officer (CFO), chief
legal officer (CLO), chief operating officer (COO),
chief human resources officer (CHRO), chief information officer (CIO), and the CCO. The executive team’s
role is to execute on the strategic plan.
The executive team meets to discuss potential
business opportunities, material risks or compliance concerns, social issues affecting patients,
employees, partners, budgetary and capital
matters, and proposed policy changes. The CEO
reports appropriate information to The Board.
Patient welfare drives executive team decisions. Our
CCO, a licensed and practicing physician, oversees
policies, procedures, and decisions regarding the
delivery of clinical patient care.
Our “patients-first” culture fostered by The Board
means our frontline professionals treat patients as
they would their family members. Our team makes
decisions on evidence-based best practices and
patients’ best interests, without regard to cost or
financial results.

Thomas Pangburn, MD
Chief Clinical Officer

Patient
welfare drives
executive team
decisions. Our
CCO, a licensed
and practicing
physician,
oversees
policies,
procedures,
and decisions
regarding the
practice of
clinical patient
care.
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II PROCESS
Corporate Responsibility Oversight
The Board sets strategic goals and KPIs for the executive team’s daily management in conjunction with the ESG Steering Committee. The ESG Steering Committee comprises our CEO, president, COO, and CFO. The Committee’s mission is
to achieve The Board’s strategic ESG goals, monitor KPIs, and oversee all ESG-related initiatives. The ESG Steering Committee supports decision-making at the
company’s highest level to influence positive changes for ESG issues.

the Board Compliance Committee. Acting through, and with, the assistance of
the Compliance Officer, the committee can investigate, evaluate, report facts,
and make recommendations to senior management regarding compliance
initiatives and possible responses to investigations, including disciplinary or
other adverse action for identified incidents of misconduct. The committee
also reviews and evaluates information received from and recommendations
developed by the Compliance Officer.

Risk Oversight
The Board provides risk oversight, delegating it to the Legal and Risk
Committee and the Board Compliance Committee. The executive team
executes risk mitigation strategy with daily activities managed through the
Legal/Risk and Management Compliance Committees.

Fl

On a day-to-day basis, the Wellpath legal, claims, continuous quality improvement, and compliance teams identify risks through ongoing analysis and review
of key metrics, including claims data, investigations, clinical events, compliance
incident reports, annual enterprise risk assessment surveys, annual audits, and
other monitoring efforts. Those teams report to the Legal/Risk, Management
Compliance, and Board Compliance Committees on these metrics quarterly,
along with recommended action plans and ongoing risk mitigation strategies.

Board Compliance Committee
The Board Compliance Committee assists in overseeing the company’s compliance with, and handling of, matters relating to the laws and regulations applicable to the company’s business. This committee reviews the effectiveness and
results of the company’s compliance program, which promotes a company-wide
culture of compliance. The committee oversees the Company’s’ execution on the
Ethics and Compliance Plan through implementation and oversight of a robust
and effective compliance program in coordination with management and the
compliance department. Committee members, including the committee chair,
are appointed by the board and include three or more members of The Board.

Management Compliance Committee
The Management Compliance Committee comprises trained representatives of
each functional department, senior management, and members appointed by
the CEO. Committee members serve at the CEO’s discretion, with oversight by

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II PROCESS

Corporate Compliance Program
In 2021, our compliance team
helped 46 sites complete thirdparty reaccreditations.

The Corporate Compliance Program is an essential part of our routine
operations. The program assesses business activities and consequent legal
risks, educates and trains personnel, implements monitoring and reporting to
measure effectiveness, and includes enforcement and discipline components
to ensure compliance.
The purpose of the Corporate Compliance Program is to ensure that Wellpath
complies with federal and state requirements of law and rule. The program exists
to identify areas of possible concern that might adversely affect the company and
works to correct those concerns.

veys that helped 46 sites complete third-party reaccreditations. Our compliance team also completed 60 on-site program audits and 60 remote desktop
audits during 2021 and provided on-site technical support to 38 sites (two
people per site for 1-2 weeks).

The program incorporates the Office of Inspector General’s seven elements of an
effective compliance program. These elements include:

• Developing effective lines of communication

These reviews identified and mitigated enterprise risks that affect the organization’s financial, reputational, or regulatory portfolios. These reviews crossed all
lines of business to assess operational practices against established company
objectives, standards, and policies. The compliance team accomplished this
through various audits depending on the site’s location, type of review required
or requested, and relevant accreditation requirements. These reviews encourage the development and introduction of best practices throughout Wellpath.

• Conducting internal monitoring and auditing

Training

• Enforcing standards through well-publicized disciplinary guidelines

Members of The Board, officers, employees, agents, and consultants participate
in our corporate compliance training program. They complete initial training
upon appointment or hire, as well as annual training, as needed or required by
policies, procedures, and regulatory changes. Compliance training focuses on
the components of our Code of Business Conduct and Ethics (Code), corporate compliance topics, and Health Insurance Portability and Accountability Act
(HIPAA) privacy and security.

• Implementing written policies, procedures, and standards of conduct
• Designating a compliance officer and compliance committee
• Conducting effective training and education

• Responding promptly to detected offenses and taking corrective action
The compliance team works closely with the Management Compliance Committee to prioritize potential risk and implement policies and procedures that
effectively reduce organizational risk. We accomplish this through ongoing monitoring of key organizational metrics, compliance incident reporting and investigations, and initial and reaccreditation audit reports and technical assistance to
achieve and maintain accreditation.

Reaccreditations and Internal Site Audits
Reviews by accrediting organizations and internal audits are representative of
our commitment to continual improvement. The compliance team continues
to prepare sites for future surveys with additional tools and mock virtual sur-

Our Compliance Training Policy ensures that training courses are issued at various levels of the organization and cover relevant company and ethical topics –
including the Code and focused patient quality education for clinicians.

Communication
Wellpath has established effective lines of communication essential for a
successful compliance program. Suspected non-compliance can be reported

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II PROCESS
directly to the compliance department or through our compliance hotline.
These reports can be made anonymously to protect the individual reporting
to the fullest extent allowed by law. The compliance department monitors
calls and emails sent to the hotline, investigates reports, and provides summary reports to the management and board compliance committees. Signs
are posted at each site to ensure colleagues know how to report a potential
compliance concern.

2021 Key Compliance Program
Accomplishments

• 100% reaccreditation rate
•	Investigated and closed more than 105 compliance incident reports
•	Completed 60 on-site program audits and 60 remote desktop audits
•	Provided on-site technical support to 38 sites (two people per site for
1-2 weeks)
•	Provided start-up support and on-site training for two months for
Georgia DOC

Investigations and Reporting
Wellpath provides employees with a confidential, non-retaliatory manner
to report potential compliance issues. Every team member has a responsibility to report potential non-compliance. The compliance department
has a Compliance Hotline Policy that describes the various means to report
concerns confidentially and even anonymously, if preferred. To ensure that
issues are easily communicated and thoroughly investigated, the compliance and the HR departments use the EthicsPoint website and hotline to
receive and resolve complaints.

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II PROCESS

Ethical Business Practices

• Compliance with applicable government and self-regulatory organization laws,
rules, and regulations

Ethical business practices define our compliance and risk mitigation efforts.
Wellpath ethics training focuses on “Always Doing The Right Thing.” Our Code
helps team members understand our commitment to ethics and compliance.
The Code deters wrongdoing and promotes honest and ethical conduct
by team members and others performing services for Wellpath and its
subsidiaries and affiliates.

• Prompt internal reporting of violations

Compliance with this Code promotes:
• Avoiding conflicts of interest
• Full, fair, accurate, timely, and transparent disclosure

• Accountability for compliance
Team members and partners can report online using the EthicsPoint Incident
Management System or call the Compliance Hotline. Additionally, team
members can complete the electronic Wellpath Incident Form or reach out to
a compliance team member directly.
Corporate compliance policies and procedures, including the Code, are
available on our intranet. Corporate compliance policies are reviewed
annually and approved by a multidisciplinary Corporate Policy Committee.

Always Do The
Right Thing!
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II PROCESS

Privacy and Data Security
Our Cybersecurity Team implements and manages our security program. Our
technologies and services comply with local, state, and federal security requirements as applicable. Security controls are a part of product planning and
designing, networks, upgrades, and other systems. We use the latest and best
tools to stay ahead of today’s rapidly evolving cyber-risk landscape.
In December 2021, our payroll and timekeeping vendor, UKG, notified us of a
ransomware attack that directly affected over 2,000 UKG served businesses
worldwide. While the outage did not compromise Wellpath data, it did halt
our access to processing payroll, and handling time sheets. In response to
the Kronos outage a multi-disciplinary team made up of 40+ key
Wellpath leaders from HR, payroll,
IT, and communications worked
In 2021, Wellpath did
nearly around the clock, to rapidly
not experience a data
stand-up alternative, in-house
breach involving
timekeeping and payroll systems
patient, people, or
to ensure team members received
their paychecks.
partner information,

including personally
identifiable
information (PII) or
protected health
information (PHI)
breaches. We had no
monetary losses from
legal proceedings
associated with data
security and privacy.

Our EHR and support systems
(e.g., finance, intranet, webmail, etc.) provide secure tools
and data storage/management
by leveraging internet-based
designs, secure transportation
protocols, and remote connectivity in isolated or physically
secure environments. Nationally
recognized firms conduct business security and HIPAA security/
privacy assessments and provide
summaries on request. Additionally, we conduct internal quar-

terly management reviews where IT leaders work with the security team to
oversee incidents and activities.
Our comprehensive cybersecurity program evaluates various technologies
and processes throughout the year. This includes IT privacy access audits,
periodic account reviews, and elevated account usage reviews. Our risk
management program identifies, analyzes, evaluates, tracks, communicates,
and manages IT risk throughout the company. This program includes regular review of key risk management components such as supply chain analysis, vendor management, security reviews of new software, and periodic
configuration audits.

Cybersecurity and Privacy
Training
Wellpath administers annual cybersecurity awareness training and shares
monthly security awareness videos
via email. We also conduct monthly
phishing tests to evaluate the effectiveness of this training. We regularly
evaluate our security tools and technologies to ensure that our security
posture remains aligned with industry
best practices.

Wellpath annual
training includes
HIPAA compliance,
safeguards,
patient rights, PHI,
compliance, and
breach reporting.

Wellpath annual training includes
HIPAA compliance, safeguards,
patient rights, PHI, compliance, and
breach reporting. We supplement this training with monthly electronic compliance chronicles, articles, and webinars.
Incident Response – The Security Incident Response Team (SIRT) comprises senior management personnel and experienced individuals from different divisions, including the director of information security, CIO, and chief
privacy officer (CPO). The SIRT team is responsible for managing the entire
incident response lifecycle by providing rapid response and recovery to
security incidents.

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II PROCESS
Breach Response
The SIRT team is responsible for communicating incident responses to consumers,
employees, third parties, and relevant customers under the direction of Wellpath
senior management, to comply with applicable laws/regulations. When a data
breach is identified, the SIRT team promptly provides the required notifications.

Protection of PHI and HIPAA
Wellpath complies with HIPAA and the Security Standards for the Protection of Electronic PHI (also known as the “Security Rule”). We take our obligations under HIPAA
Privacy and Security seriously. All Wellpath team members must adhere to physical,
technical, and administrative safeguards established in the federal HIPAA Privacy and
Security standards. Our HIPAA Privacy and Security policies protect the privacy and
confidentiality of all PHI, hard copy and electronic, whenever team members use it.
Individuals requiring access to PHI in the course of their jobs must read and
acknowledge the policies, attend annual HIPAA training for both privacy and
security, and safeguard each patient’s health information by:
• Reporting HIPAA concerns to the site department head or CPO
• Locking unattended workstations to protect computer assets
• Securing all doors (confirming no doors are propped open)
• Never sharing passwords or ID badges
• Always wearing ID badges
• Never leaving patient information unattended
We report incidents directly to the CPO or through the compliance hotline or by
completing a HIPAA Incident Report Form. HIPAA Privacy and Security compliance is reported at management and board compliance committees regularly.
Our secure EHR platform maintains and transfers PHI consistent with the confidentiality and security requirements of each facility in which it is deployed. Data
and information conforms with HIPAA, Health Information Technology Economic and Clinical Health (HITECH) Act, NCCHC, and Digital Asset Management
(DAM) protocols and other applicable laws, rules, and regulations. Cyber data,
including healthcare records, are managed and maintained within a network that
uses DAM protocols and is HIPAA and NCCHC compliant. Nationally recognized

firms conduct annual Systems and Organizational Controls (SOC 1 and SOC 2)
audits of our data center and biennial HIPAA risk assessments covering both
privacy and security requirements.

Key Components of
HIPAA Privacy and
Security Program
• Review policies and procedures
•	Monitor and review changes in
privacy laws and regulations
•	Conduct periodic compliance
assessments to ensure
agreements and safeguards are
implemented and maintained
with vendors and subcontractors
• Conduct training and audits
•	Cooperate with partners and
state and federal agencies,
including the Office for Civil
Rights of the Department of
Health and Human Services,
in compliance reviews or
investigations.

The Wellpath Information Technology Contingency Plan includes
procedures to recover IT systems
following a disruption. We test our
fail-over and recovery plan every
six months during disaster recovery
drills. All data is maintained in a
secure and redundant environment
to ensure accessibility and continuous maintenance of all patient
information, despite natural or
man-made catastrophes.
Our primary data center is co-located
in a Tier 3 data center. The TierPoint
data center ensures critical IT systems, applications, and data are safe
from tornadoes, hurricanes, earthquakes, fires, floods, and other natural
or man-made disasters. It contains
state-of-the-art infrastructure to
meet the highest level of reliability.
This facility is audited annually under
Statement on Standards for Attestation Engagement (SSAE) 18 SOC
2 Type II, Gramm-Leach-Bliley Act
(GLBA), and HIPAA standards.

Wellpath does not share PHI except as allowed under HIPAA. We maintain strict compliance with HIPAA and secure business associate agreements with third parties that
potentially could contact PHI. Wellpath respects that our partners own their data and
does not make records available to others except when approved by them. We prepare
statistical analysis reports for industry groups and others with partner permission.
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II PROCESS

Procurement
Our Procurement Team supports patient care by securing quality goods and
services that meet our operational healthcare needs.
Responsible Stewardship of Funds – The Wellpath procurement department
monitors supply chains, negotiates contracts with vendors, and serves as our
primary buyer of goods and services. Our procurement department uses the
seven-step sourcing process, which includes:
1.

Conducting an internal needs analysis

2.

Assessing the supplier market

3.

Collecting supplier information

4.

Developing a sourcing strategy

5.

Implementing the sourcing strategy

6.

Negotiating with suppliers and selecting the winning bid

7.

Implementing a transition plan or contractual supply chain improvements

By following the seven-step sourcing process, we ensure responsible stewardship
of our company’s and our partners’ resources and provide the best products or
services, on time, at the right quantity and price.
COVID-19 caused difficulties in the global supply chain. In 2021, we continued
operation of our central warehouse and distribution center in St. Louis, Missouri,

“Correctional health care services are a unique
operation and need to be responsive, flexible, and
committed. We continue to find Wellpath to be good
stewards of the County’s funds, responsive to the
needs of the agency and those we are charged with
caring for, and adaptive to the shifting challenges.”
Sheriff Tim Svenson, Yamhill County Sheriff’s Office,
McMinnville, Oregon

which we established in 2020. It allowed us to circumvent regional supply
shortages by receiving materials from international and domestic vendors
and distributing those supplies to our facilities across the country. To assist
our team on the frontlines with forecasting their supply needs, we established
standard par levels and assisted with burn rate analysis at our sites. Our team
ordered testing supplies and PPE through an online ordering portal we built to
support them. We searched the open market to fulfill needs from back orders
and cancelled items from our major distributors and cared for our existing
equipment with ongoing maintenance programs.
Supplier Code of Conduct – Wellpath is committed to ensuring vendor partners
have safe working conditions and their employees are treated with respect. In
2022, we will publish our code of conduct and continue to partner with environmentally friendly suppliers.

• Wellpath partners with medical supply leader, McKesson, which was recognized by ESG analytics as one of 2021’s five best ESG companies in healthcare.

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Efforts to Reduce Carbon
Emissions

Pollution, Waste, and
Recycling

Home Office Relocation

Responsible Recycling

Chapter 7
Planet
“The Earth is what we all have in common.”
– Wendell Berry

II PLANET

Wellpath strives to conserve
environmental resources.
We implement strategies,
such as increasing on-site
testing and treatments,
implementing best delivery
practices, optimizing
shipments, and recycling to
reduce the dependency on
environmental resources
and save taxpayer dollars.
We generally do not own
the buildings in which
we operate, however we
continue to implement
strategic processes that
decrease our carbon
footprint. We want to leave
the planet in better shape
than we found it.
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II PLANET

Efforts to Reduce Carbon Emissions
Wellpath is committed to reducing carbon emissions throughout the
organization by:
• Fleet – Our fleet comprises approximately 200 vehicles, roughly 150 of which
are leased vehicles used by our RDOs to travel to and from our partner locations. The remaining vehicles are leased by our Recovery Solutions division
and used for patient transport or other location maintenance activities. By
implementing strategic planning, our vehicles are monitored and replaced on
an as-needed basis.
• Optimization of On-Site Care – Our care philosophy includes providing
on-site care when clinically appropriate. Our on-site services include mobile
radiology, on-site dialysis, and on-site physical and occupational therapy. By
providing these and other group on-site services, multiple patients can be seen
by one specialist which reduces the frequency of individual off-site transports.
Furthermore, we are expanding our technological infrastructure, including the
Wellpath Healthcare Cloud, which will continue to reduce the frequency of
patient off-site transports, ultimately resulting in reduced carbon emissions.
• Fewer Deliveries – Wellpath works with vendor partners to ensure industry best practices for shipping and delivery. Wherever possible, we leverage
private distributor fleets rather than using commercial carriers. We train our
team members to manage inventory and use Periodic Automatic Replenishment (PAR) levels for key items. We conduct an analysis of our procurement
practices at our locations and adjust to optimize deliveries. We utilize a “Hold
to Complete” process at our new locations. By scheduling one delivery with
several hundred items at a time, we are able to complete our shipments with
fewer vehicles.

Pollution, Waste, and Recycling
Wellpath has implemented practices to minimize the quantity of expired pharmaceuticals destroyed. We follow federal, state, and local laws and regulations
when disposing of pharmaceutical waste, and we conduct audits to minimize
the presence of discontinued or expired medications. We secure medical
waste until it is destroyed. Our pharmaceutical providers work closely with us
to ensure we have the right quantity of medications on at the right time.

Type of Asset

Number
Recycled

All-in-One

564

Laptop

703

LCD Monitor

209

Printer/Copier/Fax/
Scanner

80

Desktop Computers

117

Docking Station

283

Tablets

47

Networking Equipment

278

Misc. Electronics

159

Desk Phones

56

Server

21

Phone System

19

Battery Backups

24

Cell Phone

5

Medical Equipment

0

Television

2

Grand Total

2,567

Hazardous Waste Shipment
Optimization
When compliant, safe, and available,
Wellpath sends hazardous waste safely
through the mail instead of relying on
weekly vendor pick-ups.

eRecycling
Wellpath has been performing environmentally responsible electronic recycling for over 10 years. Our
information security policy requires
that data must be wiped from all hard
drives to ensure patient and team
member privacy. Wellpath currently performs our recycling with two
partners, Computacenter and Excess IT Hardware (EIH). EIH, a social
enterprise, donates 10% of every
project to charity through recycling of
end-of-life electronics. EIH monetizes
recycled electronics to fund charities
of their client’s choice. Last year, EIH
donated $40,000 to various groups
focused on people impacted by Alzheimer’s and dementia. All donated
goods are recycled securely, ethically,
and efficiently according to federal,
state, and local Environmental Protection Agency (EPA) regulations. EIH is a
Microsoft Registered Refurbisher and
is registered with The Florida Department of Environmental Protection.
Computacenter (through Sturgeon)
adheres to a zero-landfill policy and
partner with certified disposal experts.

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II PLANET

Home Office Relocation
In 2022, our home office is moving to a smaller, more efficient office space
that promotes a hybrid work environment. Reducing the number of employees who drive to work is expected to have a positive impact on carbon
emissions. The new facility will have motion sensors on all lights to reduce
electricity consumption and a secure printing feature that will save paper.

Stericycle’s Shred-It Recycling Process

Confidential documents are dropped
into a secure, locked console.

On a scheduled basis, consoles are
emptied and all confidential
documents are destroyed.

A certificate of destruction
is issued to each customer.

Shredded paper is transported to a
paper mill for recycling.

Responsible Recycling
Wellpath works with best-in-class vendors to provide responsible waste
disposal and recycling. Each year, our recycling partner Stericycle calculates
and provides us with a summary of the environmental resources saved by
our recycling efforts. According to the Stericycle 2021 report, we:
• Recycled 371,045 pounds of paper recycled
• Saved 557 cubic yards of landfill space
• Saved 3,171 trees
• Saved 70,499 gallons of oil
• Saved 1,298,658 gallons of water

• •
•••••
•••••••
••••••
••••••
•••
• •••

•::~-:-:

-

•••••••
•••••
•• •

Pulp is made as the fibers of the
shredded paper are separated.

The pulp is put through a screening
process that filters out impurities and
prepares if for the removal of printing ink.
The newly recycled pulp is mixed
with fresh pulp to manufacture
new paper products.

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Chapter 8
Performance

II Performance
Data presented is for U.S. operations only and is as of 12/31 unless otherwise noted.

Purpose
Activity Metrics

20201

2021

Total employees

14,204

14,265

Number of site service contracts3

328

308

Number of facilities

468

567

243,316

242,791

20201

2021

Percentage of female total workforce

77.3%

78.1%

Percentage of female mid-level managers5

69.4%

67.4%

Percentage of female senior leaders6

44.3%

44.7%

Percentage of American Indian/Alaska Native

0.6%

0.6%

Percentage of Asian

4.5%

4.7%

Percentage of Black /African American

33.5%

34.0%

Percentage of Hispanic/Latino

9.8%

9.0%

Percentage of Native Hawaiian /Other Pacific Islander

0.4%

0.3%

Percentage of two or more races

2.8%

2.7%

Percentage of unknown /undeclared

0.1%

0.1%

Percentage of White

48.4%

48.5%

Percentage of non-White total workforce

51.6%

51.4%

Percentage of non-White mid-level managers5

34.7%

36.0%

Percentage of non-White senior leaders6

21.9%

23.3%

2

3

Annual ADP 3,4

People
Team Member Diversity
Female Representation

Ethnic Representation7

 ata for 2020 has been updated from the values reported in the 2020 report due to a historical records review and update of category definitions.
D
Includes full-time, part-time and PRN employees | 3 Data includes Correct Care Australasia. | 4 Average of monthly ADP. Includes U.S. and international divisions.
5
Mid-level managers include supervisors, managers, directors, and team members that either have direct reports or oversee a functional department within the organization.
6
Senior leaders include vice-presidents, executives, and the c-suite. | 7 Non-white includes all ethnic categories except White and unknown/undeclared (“None”).
1

2

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II Performance

People
Team Member Diversity

2020

2021

Percentage below 20

0.0%

0.1%

Percentage between 20-29

14.1%

12.8%

Percentage between 30-39

28.1%

27.2%

Percentage between 40-49

24.5%

24.6%

Percentage between 50-59

19.9%

21.3%

Percentage above 60

11.6%

12.4%

Percentage unknown

1.7%

1.6%

Retention/Turnover | SASB Code: HC-DY-330a.1

2020

2021

Percentage of team members retained with tenure > 1 year

82.9%

77.8%

Percentage of voluntary turnover for medical doctors

15.7%

18.1%

Percentage of voluntary turnover for non-physician medical professionals

17.1%

30.4%

Percentage of voluntary turnover for all others

24.5%

27.7%

Percentage of involuntary turnover for medical doctors

2.9%

6.3%

Percentage of involuntary turnover for non-physician medical professionals

1.5%

6.6%

Percentage of involuntary turnover for all others

6.7%

5.6%

20202

2021

Number of safety courses completed

44,122

53,397

Number of safety training hours4

28,904

23,365

Age Representation

Safety Training1
3

1

 ourses include the following topics OSHA-related topics: Active Shooter, Hazard Communications, Bloodborne Pathogens, Emergency and Disaster Preparedness, Security Awareness, Infection Prevention
C
and Control, Injury and Illness Prevention, and Violence Prevention in Healthcare.

2

The number of safety courses completed and corresponding number of safety training hours for 2020 have been updated from the values reported in the 2020 ESG Report due to a historical records review.

3

Number of courses completed by active employees during the reporting year. Training year is from March 1st through February 28th.

4

Number of hours for completed courses are per estimated completion time.

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II Performance

People
Health and Safety SASB Code: HC-DY-320a.1
(All Wellpath team members – see notes for context)

1

Correctional
Institutions1
(State Government)

Nursing and Residential
Care Facilities1
(State Government)

2020

2021

TRIR2

9.2

13.7

4.9

4.4

DART Rate3

6.4

9.7

2.7

1.7

LTIR 4

6.0

8.5

1.9

1.0

Number and rate of fatalities because of work-related injury5

0

0

Number of high-consequence work-related injuries (excluding fatalities)6

0

0

Number of recordable work-related injuries7

497

330

Percent of locations with no work injuries8

66%

67%

U.S. Bureau of Labor Statics, 2020 Benchmarks. The North American Industry Classification System (NAICS) codes presented are: 623 – Nursing and residential care services and 92214 – Correction institutions.

2

Total recordable incident rate (TRIR) - The number of recordable incidents per 100 employees. Calculation = number of incidents x 200,000/total number of hours worked in a year.

3


Days
away, restricted, or transferred (DART) rate - The number of recordable incidents per 100 employees that resulted in days away from work, days of restricted work activity, and/or days of job transfer. Calculation = number of incidents that resulted in days away, restricted or transferred x 200,000/total number of hours worked in a year.

4


Lost
time incident rate (LTIR)- The number of recordable incidents per 100 employees that resulted in employee missing work. Calculation = number of incidents that resulted in missing work x 200,000/total
number of hours worked in a year.

5

Number and rate of fatalities because of work-related injury - The number fatalities as a result of work-related injury. Calculation = number of fatalities x 200,000/total number of hours worked in a year.

6


High-consequence
work-related injuries (excluding fatalities) - The number high-consequence events (non-fatal) because of work-related injury. Calculation = number of high-consequence work-related injuries x 200,000/total number of hours worked in a year.

7

Recordable work-related injuries - The number of recordable work-related injuries. Calculation = count of injuries.

8

% of locations with no work injuries - The percentage of locations with no work injuries. Calculation = the number of locations without work injuries/the total number of locations.

/ 78 /

II Performance

Patients
Telehealth Interactions1

2020

2021

164,196

135,004

276

2,587

Number of patients treated on-site

42

1,388

Number of other synchronous interactions

163,920

133,616

122,030

346,944

121,143

297,166

887

49,778

286,226

482,148

2020

2021

232

401

20205

20216

71.54

49.90

Number of synchronous interactions2
Number of Wellpath Now consults

3

Number of asynchronous interactions4
Number of online specialty referrals
Number of other asynchronous interactions
Total Interactions

Patients Saved with Narcan®
Number of patients saved with Narcan

®

Partners
Net Promoter Score®
Net Promoter Score®

1

 he number of synchronous interactions decreased from 2020 to 2021 along with pandemic-related national trends. More patients were seen remotely during 2020 when the workforce was working
T
remotely, and less during 2021 when providers resumed more on-site care.

2

Synchronous interactions are real-time telehealth interactions.

3

The Wellpath Now service was piloted through an outside vendor in 2020. It began internally in April 2021.

4

 synchronous interactions for 2020 include e-consults and online specialty referrals. For 2021, asynchronous interactions include e-consults, online specialty referrals, teleradiology, tele-audiology,
A
and tele-wound care.

5

Data for 2020 has been updated from the values reported in the 2020 report due to a historical records review and update of category definitions.
 he decrease in net promoter score from 2020 to 2021 was primarily related to staffing challanges.
T

6

/ 79 /

II Performance

Process
Privacy & Security

2020

2021

0

0

0.0%

0.0%

0

0

0.0%

0.0%

0

0

Percentage of women

22%

22%

Percentage of Black/African American

11%

11%

Percentage of Hispanic/Latino

11%

11%

Percentage of Asian

11%

11%

Percentage of independent individuals

33%

33%

Combined years of professional experience

252

261

Number of internal program audits completed

169

120

Number of compliance incident reports investigated and closed

60

105

Pollution, Waste & Recycling

2020

2021

Number of electronic assets recycled

2,047

2,567

436,910

371,045

Number of trees saved

3,734

3,171

Gallons of oil saved

83,013

70,499

1,529,185

1,298,658

Number of data breaches - total
Percentage of data breaches involving PII
Number of customers impacted in data breaches involving PII
Percentage of data breaches involving PHI
Number of customers impacted in data breaches involving PHI

Governance
Board of Managers Composition

Compliance

Planet 1

Pounds of paper recycled

Gallons of water saved

1

With the exception of electronic assets recycled, data included in this table is calculated by Stericycle, a third party recycling contractor.

/ 80 /

II Performance

SASB Index
Topic

Accounting Metric

Code

Page Number(s)

Employee Health & Safety

(1) Total recordable incident rate (TRIR) and (2) days away, restricted,
or transferred (DART) rate

HC-DY-320a.1

52, 78

Employee Recruitment,Development &
Retention

(1) Voluntary and (2) involuntary turnover rate for: (a) physicians,
(b) non-physician health care practitioners, and (c) all other
employees

HC-DY-330a.1

45, 77

Employee Recruitment, Development &
Retention

Description of talent recruitment and retention efforts for health
care practitioners

HC-DY-330a.2

43-45

Patient Privacy & Electronic Health Records

Description of policies and practices to secure customers’
protected health information (PHI) records and other personally
identifiable information (PII)

HC-DY-230a.2

68-69

Patient Privacy & Electronic Health Records

(1) Number of data breaches, (2) percentage involving (a)
personally identifiable information (PII) only and (b) protected
health information (PHI), (3) number of customers affected in
each category, (a) PII only and (b) PHI

HC-DY-230a.3

15, 68, 80

Patient Privacy & Electronic Health Records

Total amount of monetary losses because of legal
proceedings associated with data security and privacy

HC-DY-230a.4

68

/ 81 /