This interview with Darryl Rhames (drrhames@drrhames.com) was conducted in late July 2019 by Adam Turteltaub CHC, CCEP, Vice President of Strategic Initiatives & International Programs, Society of Corporate Compliance and Ethics & Health Care Compliance Association

Darryl Rhames, Director of Compliance Auditing, Integrity Services, University Health System, San Antonio, TX

AT: You came to compliance with a background in both internal audit and as a fraud examiner. How did (or didn’t) those positions prepare you for your compliance role?

DR: As an internal auditor, I was trained to review policies and procedures and ensure adherence to applicable regulations. Similarly, in a compliance role, the aspect is the same. Furthermore, one of the major roles of a compliance officer is to monitor to prevent fraud, abuse, and waste. As a fraud examiner, you take into account how opportunities to commit fraud can be eliminated or limited. This skill helps to assess risk and assists with building and monitoring options or selecting fraud-based compliance projects for the work plan.

AT: I think it’s interesting that at University Health System you sort of transitioned from audit to compliance. You started in internal audit, then moved into compliance auditing, and then onto the compliance team. What did you learn as moved through that process?

DR: I learned the difference between the two functions and how they can help one another. For example, an internal auditor can review and evaluate the design and effectiveness of the compliance function, which allows for learning both functions. On the other hand, as related to management, compliance has the functionality to provide guidance to departments regarding policies and procedures, whereas internal audit is limited on having that type of consulting relationship due to rules of independence.