James Rough





  • Citizens Academy Graduate, FBI
  • Certified Fraud Examiner (CFE), Association of Certified Fraud Examiners
  • Certified in Healthcare Compliance (CHC), Compliance Certification Board
  • Certified Compliance and Ethics Professional (CCEP), Society of Corporate Compliance and Ethics
  • Client Service Hall of Fame 2009 and 2010, Navigant Consulting

Jim Rough

Healthcare Compliance, Forensic Investigation, Fraud Investigation

James Rough is President of SunHawk Consulting, LLC. a U.S. based Disputes, Compliance and Investigations Consulting Firm with experts in the Healthcare, Life Sciences, and Insurance Industries. Mr. Rough is a Certified Healthcare Compliance Professional, Certified Fraud Examiner, Certified Compliance and Ethics Professional and graduate of FBI Citizen’s Academy. Mr. Rough has also served on the Audit Committee of the Board of Directors for two entities and is adjunct professor focused on Healthcare Compliance, for the Masters of Legal Studies Compliance Program, at Arizona State University, Sandra Day O’Connor, College of Law. 

For 20 years, U.S. and international clients have trusted Mr. Rough to perform independent fraud investigations, compliance effectiveness assessments; consult on complex contract disputes including quantification of damages; perform complex data analytics on large datasets and perform sample selections using various methods. He has also served as an independent technical advisor to State Auditors and the Centers for Medicaid & Medicare Services (CMS).  Mr. Rough’s unique combination of formal financial, fraud and forensic training is coupled with significant experience in various healthcare industry segments and familiarity with associated large transactional, financial, and regulatory data sets. This knowledge base provides clients with a multi-faceted expert when they are facing compliance, internal and external investigation, litigation, financial accounting, and other compliance challenges. 

Mr. Rough regularly advises clients on multiple topics, including the False Claims Act, Affordable Care Act, Stark Law & Anti-Kickback Statute, Medical Loss Ratios (MLR), Usual and Customary Rates in Healthcare Industry, Claims Data Analytics, Fraud Prevention and Investigation, Statistics including proper use of RAT-STATS software and technical accounting for revenue recognition. Mr. Rough’s healthcare clients include some of the nation’s largest insurers, hospital systems, global medical device/implant manufacturers and utilization managers. 

Mr. Rough has led or had significant roles in high-profile forensic investigations and compliance reviews domestically as well as in Europe and the Middle East. Mr. Rough has provided significant support to clients communicating complex issues to regulatory and enforcement personnel, including the Department of Justice (DOJ) and Health and Human Services (HHS) – Office of Inspector General. He has communicated investigation and/or audit findings directly to CMS, State Medicaid Auditors, and to the Securities and Exchange Commission’s (SEC) enforcement personnel.  Mr. Rough has also served as a non-testifying subject matter expert to white-collar defense counsel in high-profile criminal DOJ, civil SEC, and class action proceedings. 

Mr. Rough is a regular lecturer for the Health Care Compliance Association (HCCA) on best practices for Communicating with Government Regulators and Enforcement personnel and Investigations. Mr. Rough serves as Chair of the annual Arizona Regional Conferences for HCCA and Society of Corporate Compliance and Ethics (SCCE), serves on planning committee for the HCCA and SCCE’s Annual Board Audit and Compliance Committee Conferences and on the planning committee for the HCCA annual Indiana Regional Conference.  Mr. Rough is also Chair of the Arizona Ethics and Compliance Council and is and adjunct professor for Arizona State University, Sandra Day O’Connor, College of Law.


"SunHawk was an outstanding partner in the provision of interim leadership in compliance and internal audit for our organization.  They provided seamless coverage and advancement of our compliance and internal audit functions.  As CEO, I had no concerns or worries during our engagement.  They were true partners for us!"


Alfred E. Pilong

President and CEO
Garnet Health

"James and the SunHawk team have been an invaluable resource for our Compliance Office - they are a reliable, well experienced, trusted and knowledgeable team of professionals who at a moment’s notice will take your calls or respond to your emails.

Their advice helped us navigate the ever evolving, highly regulated healthcare industry!  Whether it’s discussing report methodology or determining appropriate repayment, SunHawk provides the reassurance and confidence that you are doing the right thing!

We are honored to have partnered with SunHawk and will continue to do so in the future!"

Natasha Cogdill

Vice President/Chief Ethics, Compliance and Privacy Officer
Community Health System

"SunHawk’s professionals are leaders in the compliance and risk industries. Over the years I have worked with a number of their professionals on a series of projects/issues and learned SunHawk’s professionals are problem/solution-oriented and great coalition builders. 

SunHawk Professionals get the job done and are a pleasure to work with. Commitment, Experience, Professionalism, and Integrity; that's what SunHawk Professionals brings to the table."

Gerry Roy

Vice President/Chief Ethics, Compliance and Privacy Officer
Phoenix Children's Hospital

"Jim Rough is among the most conscientious professionals I have encountered. When he says he is going to do something -- he does it. Jim has a broad range of experience gained over decades in leading organizations.

Now as the founder of his own firm, Jim will be enabled to provide the same high-quality service to his clients in a setting that allows greater customization to his clients' financial circumstances."

Frank M. Placenti

Chair, US Corporate Governance & Securities Regulation
Practice, Squire Patton Boggs

"SunHawk Consulting's HIPAA Check Program provided us with an invaluable third-party review of our HIPAA policies and practices. The tracking tool SunHawk includes with the Program has become an integral part of our continued monitoring for HIPAA compliance.

Jan Elezian's extensive hands-on compliance experience was evident during site visits and staff interviews as she translated difficult subject matter into practical use scenarios and provided quality feedback. Thank you SunHawk team!"

Nancy Lipman

Vice President, Compliance
Chicanos Por La Causa, Inc.

"SunHawk provides an array of dynamic professionals, each with significant subject matter expertise and a problem-solver approach. Beyond their knowledge and conscientious work ethic, however, is a team of caring individuals who strive to furnish individualized, tailored assistance with a personal touch. 

Jim Rough's dedication to the success of SunHawk clients is evidenced by his strategic and prospective thinking complemented by his ability to truly anticipate the needs of a company in the midst of the complicated compliance climate. I highly recommend SunHawk for companies of any size seeking actionable solutions and measurable results."

Michelle Missal

Vice President and Chief Compliance Officer
Paragon 28, Inc.

Get In Touch

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SunHawk Consulting

2550 E Rose Garden Ln.
Unit 72016
Phoenix, AZ 85050

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