Meet Daniel Roach - Society of Corporate Compliance and Ethics

Volume one
Number one
July 2004
Published Quarterly
Meet
Daniel Roach
Vice President,
Compliance and Audit,
Catholic Healthcare West,
and Chairman, Society of
Corporate Compliance
and Ethics
REGISTER TODAY!
3RD ANNUAL CORPORATE RESPONSIBILITY SYMPOSIUM
AUGUST 23-24, 2004 • REDMOND, WA
MICROSOFT CORPORATE CONFERENCE CENTER
For more information go to the SCCE Website,
www.corporatecompliance.org or see page 24 of this issue.
INSIDE
Leadership letter
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feature
article
Meet Daniel Roach
Vice President, Compliance and Audit, Catholic Healthcare West
Chairman, Society of Corporate Compliance and Ethics
July 2004
20
Editor''s note: The following interview
was conducted by Rory Jaffe, MD, MBA,
C&E Editor-in-Chief and Chief
Compliance Officer for UC Davis Health
System, in July 2004, with Daniel Roach,
Vice President, Catholic Healthcare West
and Chairman, Society of Corporate
Compliance and Ethics.
RJ: Mr. Roach, if you would, please
describe your background and your current
role as Vice President, Compliance
and Audit of Catholic Healthcare West?
DR: I am an attorney by training, and
have spent all my professional career in
healthcare, first as in-house counsel
with several healthcare systems and
then with CHW in my compliance and
audit roles. My role in compliance is to
oversee the development and operation
of the compliance program at CHW,
focused particularly on ensuring the
organization complies with nearly
150,000 thousand pages of complex,
confusing and sometimes counterintuitive
laws, regulations, guidance and
instructions.
RJ: I understand you are the
Chairman of the Society of Corporate
Compliance and Ethics, would you
briefly describe the organization (ie. Its
mission, background and membership)?
DR: The SCCE was formed to promote
compliance and ethics in all types
of business organizations. The corporate
world has seen an unprecedented
number of ethical lapses and illegal
conduct that has raised real questions
about how businesses are operated.
The goal of the SCCE is to provide a
forum for representatives of business to
come together and share ideas on how
to effectively promote compliance and
ethics in the workplace.
RJ: What is the name of the SCCE
website and what information can we
find there?
DR: The society website is www.corporatecompliance.org.
The SCCE website
is updated daily with educational
event listings for both the SCCE and its
partners, the SCCE electronic newsletter,
membership information, compliance
resources, products and links
RJ: Can you describe the type of professionals
who join the association?
DR: The SCCE is intended to support
those who have responsibility for compliance
and ethics within the organization.
In some cases it is an eithics or
compliance officer, in other cases it is
the head of internal audit, in-house
counsel, or even the CEO or CFO. Our
goal is to function as a resource to our
members. Many years of experience in
the compliance field have convinced me
that this task is much easier if we share
information and ideas - the SCCE will
serve as the catalyst for that sharing.
RJ: Education is a large component
of SCCE activities. Could you tell us a
little bit about some of the meetings
that you are going to be having in 2004.
DR: Our annual meeting will occur
in Seattle on August 23rd and 24th. We
have a great line-up of speakers that
will should both stimulate and challenge
the participants. Some of the
speakers include Scott W. Friestad,
Assistant Director, Division of
Enforcement, US Securities and
Exchange Commission; Paula Desio,
Deputy General Counsel, United States
Sentencing Commission; Cecilia Ochoa
Levine, Federal Reserve Board Member,
President's Export Council Member,
Society of Corporate Compliance and Ethics • (888) 277-4977 • www.corporatecompliance.org

President, MFI International Mfg. LLC.;
Howard M. Radzely, Solicitor, U.S.
Department of Labor. Later in the fall
we have a series of one day workshops
across the country that are designed to
orient people to the foundations of
compliance and help them begin to
develop a compliance program in their
organization.
RJ: What is a typical member interested
in getting out of their involvement
with the SCCE?
DR: I think that the main interest is
to take a difficult and complicated challenge
and figure out how to meet that
challenge effectively and efficiently.
Bringing together professionals from a
variety of industries and backgrounds
with experts in the field of compliance
is the principal mission of the SCCE.
RJ: Are companies outside of the
healthcare industry approaching compliance
and ethics programs differently
than healthcare?
DR: Every industry and indeed every
company will approach compliance a
bit differently. However, the foundations
for and effective program are the
same across all industries.
Understanding the Federal Sentencing
Guidelines and the very specific elements
of an effective compliance program
is an essential starting point for
any organization attempting to build a
program. The substance of the program
will vary from industry to industry, but
the basic framework and components of
the program will be very similar across
all industries.
RJ: What is the difference between
legal compliance and business ethics?
DR: Ask one hundred people this
question and I am sure you will get at
least as many answers. However, in my
view compliance is the obligation to follow
the laws and its focused on ensuring
that employees understand the laws,
rules and company policies which apply
to their job function. Ethics is focused
not only on complying with the law,
but doing business in a way that helps
preserve and protect the organization's
reputation and recognizes that there are
obligations to society beyond the bottom
line.
RJ: Do you think that a legal background
is an advantage or a disadvantage
for a compliance officer?
DR: Yes. My legal background has
helped me tremendously. It helps me
understand difficult laws, to evaluate
the consequences of improper conduct
and communicate effectively with management.
At the same time, lawyers
frequently lack the operational knowledge
and background necessary to
effectively implement programs and efficiently
monitor adherence to the program.
Ultimately a program is successful
only if it is consistently and effectively
executed. Ideally, pairing legal
expertise with operational experience is
a very effective way to develop and
implement a program.
RJ: If the compliance officer does
not report to the general counsel what
is the general counsel's role in compliance?
DR: I believe that an effective compliance
program requires the collaboration
of the compliance officer and the
general counsel. Organizations that
have the most effective programs are
those where the compliance officer and
the general counsel work as a team.
RJ: What is the Boards most important
role in compliance other than setting
the tone and being supportive?
DR: The board of directors in an
organization is ultimately responsible for
compliance. A board which does not
ensure that the organization has a program
in place to prevent and detect violations
of law has probably failed to
appropriately exercise its fiduciary obligations.
In my view the role of the
board (either directly or through the
audit or compliance committee) is to
ensure that the organization develops a
program that is consistent with the
organizations activities, devotes the
resources necessary to effectively implement
the program, creates management
incentives sufficient to ensure that the
program gets adequate management
attention, and receive periodic reports
on the effectiveness of the program. •
Society of Corporate Compliance and Ethics • (888) 277-4977 • www.corporatecompliance.org
RORY JAFFE
July 2004
21