KFF Standards and Practices

Introduction

This document’s intent is to serve as a roadmap that sets expectations clearly for how we work together and behave in a principled and ethical manner. It applies equally to all KFF staff across the board as well as for any freelancers doing work under our direction. Given the current proliferation of misinformation and declining trust in expertise and evidence, our work is more important than ever. Maintaining trust is especially critical and is attained not only through the quality of our work but also through the professionalism and ethical conduct of our staff. Who we are as a staff and how we conduct ourselves in the workplace and outside of work maters as it can reflect directly on KFF’s credibility.

Our Values: Who We Are as a Staff

At KFF, we hold ourselves to the highest standards of conduct, guided by a set of core values that shape our interactions, decisions, and work. These values are more than just words. They are the foundation of our culture and the principles that guide us in everything we do.

Mission Driven: We are mission driven individuals who are all a part of one extraordinary organization working towards a common goal of keeping facts, truth and people at the center of our health care policy debates and discussions.

Non-Advocacy: We are not here to advocate or advance any policy position or outcome, but to inform and shape discussion and amplify people’s voices in public debates.

Collaborative: We are fiercely anti-fiefdom and share information across our teams, soliciting input from colleagues organization wide in order to maximize KFF’s impact.

Diversity and Equity: We are strengthened by the different perspectives and experiences represented on our staff and our Board and we seek diversity across the organization. Greater social, economic, and racial equity motivates the work we do.

Collegiality and Tolerance: We are collegial, compassionate, and tolerant of one another and we value each individual’s self-expression.

Professional Fulfillment: Our work is professionally fulfilling and we are professional in conducting our work with commitments to accuracy and integrity.

Continuous Improvement: We are an organization committed to continual improvement, evolution and change.

Upholding Our Values: Standards of Conduct Guidelines for Our Organization

The standard guidelines outlined below are informed by KFF’s organizational values and our policies. We recognize that the potential consequences of certain activities described below are likely to vary considerably depending on the role and public profile of a given staff person. In addition to these guidelines, KFF staff may adhere to other professional norms or guidelines such as those promulgated by journalism associations, the American Association for Public Opinion Research, the American Institute of CPAs, or other groups relevant to their professions. These industry-specific guidelines are additive and do not replace these KFF guidelines. Staff members are expected to use their best judgment and consult with the senior leadership of their departments when a correct course of action is not clear.

KFF also engages non-employees, such as temp workers, freelance journalists, and other independent contractors who provide services and work product for our staff in various capacities. Individuals who fall into these categories should adhere to the provisions outlined in this document as appropriate for the work they are undertaking for KFF. Managers are responsible for inquiring about a freelancer’s potential conflicts of interest and responding in accordance with what is laid out in this policy.

Fidelity to Mission:

KFF’s mission, serving as the independent source of information on national health issues, is our North Star. It informs our culture, our values and, from our respective program areas to our administrative and operations teams, it guides the work we produce every day. Serving our mission is an expected priority for all KFF staff.

Ethical and Responsible Engagement:

General Principles: Maintaining professional integrity and impartiality are critical to KFF’s credibility and reputation as a trusted source of information and analysis in the health care policy landscape. Accordingly, staff must ensure that they use good judgement in their approach to their work and engagement in external activities to ensure they don’t compromise KFF’s nonpartisan stance and credibility. Every effort must be made to avoid situations that create a conflict of interest between KFF and others. Even the appearance of a potential conflict — any activity, relationship, investment, or affiliation that reasonably could be perceived as affecting your judgment or indicating a bias — is problematic and should be avoided or discussed internally if there is uncertainty.

Financial Ties and Investments: KFF believes in avoiding financial ties with anyone involved in the areas our work focuses on or with any entity having a current or potential business relationship with KFF (except stock ownership of less than 1% interest). To the best of their knowledge, staff members may not own individual securities (stocks, bonds, or other instruments) in any company that falls within areas that they analyze or report on. In no circumstances should KFF staff allow personal investments or financial relationships to influence their work. They may not use nonpublic information obtained by KFF to make personal investment decisions.

Political Advocacy: KFF’s independent nonpartisan stance is crucial to its continued credibility as a source of unbiased and reliable information on national healthcare issues. As an organization, we do not engage in lobbying or take positions on policy, and we strive for balance in our approach to our work. While we encourage civic engagement and we strongly support staff’s expression of First Amendment rights, we expect staff to avoid engaging in overtly partisan activities in a manner that undermines KFF’s independent reputation. Potential fallout from political advocacy activities could be especially damaging for certain staff (e.g., journalists or others with public-facing profiles). Examples of activities that should be avoided include but are not limited to:

  • Electioneering in public forums in your capacity as a KFF employee for any political candidate or cause.
  • Running for or accepting an appointment to public office.
  • Politically partisan social media platform usage (see the “online conduct and activity” section below for more on this).

Other activities may also be harmful to one’s personal reputation, or that of KFF, and staff should be mindful of the impact of engaging in such activities and consider their specific role at KFF and public profile in making such a determination. The following are examples of activities where staff should exercise careful judgement. If you have any questions about such activities and whether they might be harmful to your reputation or that of KFF, consult your supervisor.

  • Expressing political views in the form of bumper stickers, lawn signs, blog posts, or online comments, even without explicit identification as a KFF employee.
  • Making campaign donations.
  • Participating in political protests.

Work Outside of KFF: Staff are expected to devote their professional time and best efforts to the performance of their jobs in the interest of KFF. In practice this means:

  • Staff may not accept any payments or honorarium, including for speeches, articles, service on boards or advisory committees, teaching, or prizes. In some cases, it is acceptable for payments to be made to KFF. Consult your manager.
  • KFF staff are sometimes invited to speak to organizations or to appear on discussion panels. Before accepting, they should consider the purpose of the event and how it might be perceived, discuss it with their manager, and obtain approval. Staff members should avoid situations in which their participation could be construed as endorsement of the sponsoring organization’s interests.
  • Staff may not accept secondary employment or any compensation for external work that in any way relates to, or conflicts with, their work at KFF or KFF interests.
  • In general, KFF staff will not be able to write op-eds as they typically require taking a position. As exceptions, op-eds “KFF style” can sometimes be written with prior review and approval by the program area head and CEO.
  • A staff member who is offered an award should consult his or her supervisor before accepting it.
  • Outside and unrelated freelance work, speeches, teaching opportunities, books, or various other activities (e.g., being paid to perform in a band) can only be undertaken in instances that are unrelated to KFF work, it doesn’t distract from KFF work responsibilities or place KFF’s credibility at risk, and no conflict exists. If there are any questions about whether any such work is acceptable, please consult with the Senior Vice President for Human Resources.
  • Part-time employees may engage in outside employment with disclosure to the Senior Vice President of Human Resources and relevant senior leadership.
  • Unpaid activities related to KFF’s work are acceptable with disclosure to your manager and the Senior Vice President of Human Resources. To the extent these activities enhance the stature and credibility of KFF and its staff and help to fulfill our mission, they are encouraged and can be considered part of your job at KFF. These activities include but are not limited to: serving on unpaid boards or advisory committees, teaching classes at universities, giving speeches or serving on panels, or writing academic articles.

Perks: Staff are prohibited from accepting any personal gifts or payments from any political organizations, health care industry or advocacy groups, or stakeholders with a current or potential tie to KFF. Generally speaking, KFF has a policy of paying our own way for work related activities. In practice, this means:

  • Not accepting honoraria for speaking engagements, or any money that comes with awards.
  • Not giving, or accepting, gifts from news sources, potential news sources, lobbying groups or others who seek to influence coverage.
  • In certain instances, accepting payment for travel to/from an engagement may be necessary and acceptable so long as it does not create the appearance of a conflict of interest. Be sure to consult with your manager and department head.

Personal Relationships: The activities of family members, companions, close friends or other personal relationships may create conflicts of interest. KFF does not have the authority or inclination to limit the activities of individuals who are not employed by us. However, because associations can create a potential conflict or the perception of one, staff should disclose any potentially problematic associations to the Senior Vice President of Human Resources and their manager. Their manager may restrict a staff member’s assignment based on the activities of a family member, companion, or close friend or on other personal relationships in the case of a potential conflict.

Awards: Staff members should not independently enter their work into contests, and our work should only be submitted to contests whose central purpose is to recognize journalistic, polling or research excellence after approval from KFF leadership. KFF does not participate in contests that exist primarily to publicize or further the cause of an organization. Under no circumstances may journalists accept awards from groups they cover. A staff member who is offered an award should consult their supervisor before accepting it. KFF staff are not able to accept cash or financial prizes due to KFF’s conflict of interest policy and should consult with their manager if questions arise. Nominations for awards are handled and approved by KFF leadership.

Staff should refrain from voting for awards or rankings in the health care field and should consult with their manager if there are any questions about what is appropriate.

Professional Conduct at Work and Outside of Work:

General Principles:

Regardless of whether you are taking part in an on-the-record media appearance or speaking about KFF and your work in person at an event, on the phone, in a Zoom box, or through social media, all KFF employees represent KFF at all times and in all settings and should always do so in a professional manner. We always adhere to legal boundaries, and we don’t wish to pry into any staff’s personal lives, but in our current climate where any public expression of inappropriate views (e.g., expressing racist views during a community board meeting during public comment), or engagement in inappropriate activity (e.g., participating in a political insurrection), it’s possible and even sometimes likely such behavior will be tied back to KFF and result in a blow to our credibility. Bottom line is that any behavior that goes against KFF’s values and compromises our reputation, even by association, is not acceptable. The following should be taken into account in both an on or offline setting:

  • Recognize that the line between private and public speech is not always clear.
  • Try to refrain from offering opinions about the news on social media, particularly those of a partisan nature and/or those that relate to KFF’s core issues.
  • Do not engage in harassment or hate speech in any setting.
  • In lieu of opinion, deploy facts. If someone wants to engage on a story you wrote or a brief you authored, you may do so, but stick to the facts. Never make it personal. Never make it petty. Never respond to insults.
  • You should always strive to be objective, informative, non-partisan, analytical, authoritative, and thoughtful. Try to avoid punditry and avoid being combative, partisan or petty.
  • In public comments, KFF staff must not express partisan opinions, promote political views, advocate for or against specific policies, endorse or oppose candidates, be disrespectful toward public figures, make offensive comments or do anything else that undercuts KFF’s reputation. We consider comportment as important as substance. A sense of humor is fine, but attacks or snarky comments do not reflect well on KFF and should be avoided.
  • Before you comment on anything in any setting, consider asking yourself: Is this something that needs to be said, is it something that needs to be said by you, and is it something that needs to be said by you right now? If you answer ‘no’ to any of the three, it might be best not to comment.
  • Work at KFF is work performed on behalf of the organization and is often the product of a team effort. Generally refrain from any form of self-promotion and branding, referring to “we” and “KFF” not “I”.

Maintain Respectful Collaboration and Communication: KFF is a culture where we respect one another, and where tone and respect for differing viewpoints mater. We strongly encourage collaboration and the sharing of information across the organization. We care about facts and evidence and consider alternate points of view in our interactions with each other and in our approach to our work. For example, assuming a combative or snarky stance can diminish trust and engagement, and is never welcome, whether expressed internally during a team meeting or externally on social media.

Online Conduct and Activity: Communicating our work is central to KFF’s mission, and our staff who do that work are our most effective messengers. All staff are encouraged, but not required, to communicate KFF’s work to their respective networks and social media channels. When you use social media and online platforms to discuss issues related to KFF work, please follow the same rules and understandings that govern the production of our fact sheets, policy briefs, poll findings, presentations, news articles, podcasts, or interactions with reporters from other news organizations.

It is understood that KFF staff may also use forms of social media and blogging platforms for personal communication unrelated to their responsibilities as KFF employees. KFF stands by the principle that all employees should be free to express their First Amendment rights, including on social media. However, should employees’ activity on social media and related online platforms compromise their ability to do their job at KFF, constitute hate speech or harassment, or compromise KFF’s credibility, such activity can become problematic when any post or like can become public even when shared on a private platform.

While you may intend for your social media accounts to be private zones, separate from your role at KFF, you should be aware that everything we post or “like” online runs the risk of being made public in the future by anyone within our networks or by a hack of any “private” network. Therefore, please use good judgment when engaging in online activity intended to be “private.” If posting political information or political endorsements in a setting you intend to be private, please ensure that no attribution to KFF is explicit or implied.

If your intention is to engage in private social media activity unrelated to your work at KFF, you should not post content related to KFF’s work or the topics we focus on, and you might consider locking your account. Recognize, however, that there is no clear line between private and public speech. That said, content you post or share that is intended to be private will not be held to the same level of scrutiny as content that is intended to be public.

The staff expectations detailed below are primarily focused on staff members’ public accounts, meaning social media accounts held by individual KFF staff and are used, in some capacity, to communicate about the work conducted by KFF, either by directly sharing reports or stories, providing insight on key topics, or linking to the organization in your profile. However, it is important to note that all social media activity by KFF staff may fall under these guidelines to some degree again by nature of the blurred definitions between online and offline today.

Staff expectations include, but are not limited to:

  • Use good judgment in online activity, recognizing that “private” is rarely so online.
  • If you engage in private social media activity unrelated to work at KFF, do not post content related to KFF’s work or the topics we focus on.
  • Do not post anything to undercut KFF’s standing as an independent, nonpartisan nonprofit organization, including statements that could be construed as advocacy.
  • If communicating our work online is not part of your role or responsibilities at KFF, please include some variation of “Posts reflect my own views” in any social media platform bio text and make similar disclosures when blogging or adding personal content through other forms of social media. Be mindful that actions including retweets, likes, shares, reposts, quote tweets, etc. may be viewed as endorsements, with or without a disclaimer.
  • We strongly discourage all KFF staff from making customer service complaints on social media.
  • Avoid joining private and “secret” groups on Facebook and other platforms that may have a partisan orientation, particularly when using your public accounts. You should also refrain from registering for partisan events using your public social media accounts.
  • Do not create fake accounts to mask your identity in order to post about health policy issues or other content related to KFF.
  • Always treat others with respect on social media. Never attack a public official, though you may question a statement by using facts and analysis in a non-partisan way.
  • Take care when using hashtags as they can take on different meanings over time and/or have different associations for different audiences.
  • We support your right to mute or block people on social media who are threatening or abusive. Please immediately report to your supervisor, KFF Human Resources, and Communications any threats or comments that cause you to fear for your physical or mental health or safety. You may also contact Ann DeFabio, who leads Communications, would like to alert your colleagues and KFF’s brands to abusive followers or have questions about our social media policies.
  • And once again, never engage in hate speech (online or offline).

Use of AI Tools: Generative AI brings the potential for task automation and insightful analysis, but also poses new challenges in terms of privacy, misinformation, and transparency. KFF encourages staff to take advantage of these tools to work more efficiently and effectively, but with a process and mindset that safeguards the organization from the problems that can arise with misuse of AI tools and platforms. Any use of AI must be disclosed and discussed with your supervisor.

Conclusion

Adhering to these principles in a manner that is consistent with our values is a requirement for all staff. We encourage ongoing open discussion with managers, senior leadership, and with Human Resources to navigate any ethical dilemmas or uncertainty that may arise. The provisions covered in this guide are subject to change so it will be updated periodically.

KFF Headquarters: 185 Berry St., Suite 2000, San Francisco, CA 94107 | Phone 650-854-9400
Washington Offices and Barbara Jordan Conference Center: 1330 G Street, NW, Washington, DC 20005 | Phone 202-347-5270

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The independent source for health policy research, polling, and news, KFF is a nonprofit organization based in San Francisco, California.