Risk & Compliance
Trilogy’s approach to Risk and Compliance is focused on identifying and quantifying the specific risk types our clients face such as cyber, human resources, information technology, operations, and strategy, while helping to manage these risks and comply with Federal guidance.
OMB Circular A-123 provides specific guidance for internal controls over financial reporting, operations, and the importance of building an effective enterprise risk management (ERM) program. We have deep experience guiding our Federal clients through the detailed process of assessing, designing, and implementing comprehensive governance, risk, and compliance programs to link risk with strategy and performance.
Utilizing the GAO Green Book and the COSO Internal Control and Enterprise Risk Management (ERM) frameworks, our approach takes the best from both Government and Industry to help our clients succeed. Trilogy also has deep grants management experience in conducting both financial and operational reviews of Federal grants utilized by grantees to serve individuals and their families.

Solution Areas
- Enterprise Risk Management (ERM)
- OMB Circular No. A-123 Design
and Assessment - Treasury Financial Manual (TFM)
Compliance - Federal Grant Funding Operational Review
Related Work:
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VFMP Post Payment Medical Claim Analysis Contract
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Audit and Oversight Support to the VA’s Grant Per Diem (GPD), Supportive Services for Veteran Families (SSVF) and Staff Sergeant Parker Gordon Fox Suicide Prevention Grant (SSG Fox SPGP) Programs
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Department of Veterans Affairs, Office of Financial Process Improvement and Audit Readiness (OFPIAR) Support Services
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VA Financial Management Business Transformation (FMBT) System Integration (SI) Support
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VA Grant Per Diem (GPD) and Supportive Services for Veteran Families (SSVF) Financial and Operational Grantee Audits
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VFMP Post Payment Medical Claim Analysis Contract
Overview
Trilogy Federal supports the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Office of Integrated Care (IVC), Integrated External Networks (IEN), Veteran and Family Member Programs (VFMP) by delivering Post-Payment Medical Claims Analytics services that strengthen financial stewardship and payment integrity. This effort supports five Congressionally mandated healthcare programs representing approximately $2 billion in annual healthcare spending, providing oversight and insight to identify improper payments, billing errors, coding discrepancies, and waste while ensuring compliance with policies and business rules.
Approach
Team Trilogy provides a multidisciplinary team of experienced Project Managers, Senior Program Analysts, and Senior Data Analysts who integrate seamlessly into VA’s Payment and Business Integrity (PBI) framework. Our approach combines advanced data analytics, industry-standard billing expertise (CPT, HCPCS, ICD, CMS/NCCI edits), and rigorous program management practices to aggregate, analyze, and interpret large-scale medical claims data. We leverage VA data systems and establish governance processes to conduct complex post-payment reviews, identify trends and risks, facilitate stakeholder coordination, and deliver clear, actionable insights to VA leadership while maintaining strict adherence to VA security, privacy, and quality standards.
Results
Through this engagement, Trilogy enhances VFMP’s ability to detect and prevent improper payments, improve claims accuracy, and optimize healthcare spending across all five programs. The team delivers executive-level reporting, process documentation, risk analysis, and ongoing program management support that increases transparency, strengthens oversight, and supports data-driven decision-making. As a result, VA leadership gains improved visibility into payment integrity risks, operational performance, and opportunities for cost avoidance—ultimately improving program efficiency and safeguarding healthcare resources for Veterans and their families.
Audit and Oversight Support to the VA’s Grant Per Diem (GPD), Supportive Services for Veteran Families (SSVF) and Staff Sergeant Parker Gordon Fox Suicide Prevention Grant (SSG Fox SPGP) Programs
Overview
Trilogy Federal, LLC provides financial and operational fitness audit and oversight support to the Department of Veterans Affairs’ (VA) Grant Per Diem (GPD), Supportive Services for Veteran Families (SSVF), and Staff Sergeant Parker Gordon Fox Suicide Prevention Grant (SSG Fox SPGP) programs on behalf of the VA’s Office of Business Oversight (OBO). Trilogy Federal’s provides assurance to VA leadership that these grants are used as intended and comply with current legislation through fiscal and operational management. Trilogy’s oversight aims to ensure each program provides the necessary tools and support services for Veterans experiencing homelessness and/or providing resources toward community-based suicide prevention efforts to meet the needs of Veterans and their families through outreach, suicide prevention services, and connection to VA and community resources across the nation.
Approach
Trilogy Federal, LLC’s audit and oversight support service teams work with individual organizations across the country who provide transitional housing and other various support services to Veterans who participate in these three individual grants. Working one-on-one with grantees and performing almost 250 reviews annually, Trilogy’s audit support teams support compliance with each program’s guidelines along with verifying management of these operations remain transparent.
Results
Since the establishment of these programs, statistics have shown the vast majority of Veterans are seeking tools and resources to combat homelessness and suicide prevention. The organizations which operate the GPD, SSVF and SSG Fox SPGP programs, work to provide tools, resources, and support to Veterans nationwide to combat the challenges they are facing. Trilogy aims to establish long-term success to Veteran housing programs, suicide prevention, and other necessary support services to each Veteran and family members in need. In FY25, the audit teams identified over $11M in questioned costs and produced nearly 2,000 recommendations that will improve services to Veterans and their families.
Department of Veterans Affairs, Office of Financial Process Improvement and Audit Readiness (OFPIAR) Support Services
Overview
Trilogy has provided OFPIAR with support in all aspects of federal financial management, including the full lifecycle of the financial statement audit, financial policy and procedure review, internal control assessments, financial systems support and accounting operations support. We provide audit liaison and audit remediation activities and are experienced in working with OIG offices as well as external independent auditors. Our staff brings in-depth knowledge of the audit process, Generally Accepted Accounting Principles (GAAP), Federal Accounting Standards and Generally Accepted Government Auditing Standards (GAGAS). Trilogy supports the VA during audit site visits and in responding to Prepared by Client (PBC) requests and Notice of Findings and Recommendations (NFRs).
Approach
During the execution of this contract, Trilogy support has included: financial process improvement and audit readiness, audit liaison, corrective action plans, NFR remediation, financial reporting, OMB A-136 compliance, preparation of financial statements, GTAS and quarterly/year-end processing, OMB A-123 compliance, internal controls assessments and process narrative reviews, accounting policy review and updates, accounting operations support and Treasury Financial Manual (TFM) compliance reviews, and financial system support and reconciliation of procurement and finance data.
Results
As trusted advisors to VA, Trilogy was relied upon to provide an enterprise level assessment of business and accounting operations and provide recommendations to leadership. We have also been able to review project management procedures and daily operational processes and make recommendations for improvement and helped VA clear an audit material weakness by redesigning the annual close cycle.
VA Financial Management Business Transformation (FMBT) System Integration (SI) Support
Overview
Trilogy operated as a system integrator for VA’s Financial Management and Business Transformation (FMBT) initiative. The program is designed to modernize VA’s financial and acquisition management systems with transformative business processes and capabilities that enable VA to meet financial management legislation objectives and directives through a solution called Integrated Financial and Acquisitions Management System (iFAMS), a custom implementation of Momentum Financials.
Approach
Trilogy supported the VA’s migration to the Momentum cloud solution, implemented as VA’s Integrated Financial and Management System (iFAMS). As part of this effort, Trilogy enabled the VA to leverage the Scaled Agile Framework (SAFe) to effectively deploy and operationalize the new solution. Trilogy provided comprehensive operations and maintenance (O&M), configuration management, requirements management, and organizational change management (OCM) services, ensuring disciplined execution and smooth adoption across the program.
Results
As a result of Trilogy’s support in transitioning to a modern, cloud-based ERP solution, VA administrations have already realized measurable improvements in transparency, accuracy, timeliness, and reliability of financial information across multiple departments with increased operational efficiency, productivity, agility, and flexibility .Trilogy has played a critical role in seven successful iFAMS implementations, enabling the phased transition of diverse VA user communities through carefully planned and executed deployment waves. These deployment waves have included the National Cemetery Administration (NCA), Veterans Benefits Administration (VBA), Veterans Health Administration (VHA), and VA Staff Offices. Trilogy’s contributions have been formally recognized and highly valued by VA as it continues its transition from the legacy Financial Management System (FMS) to iFAMS.
VA Grant Per Diem (GPD) and Supportive Services for Veteran Families (SSVF) Financial and Operational Grantee Audits
Overview
Both the SSVF and GPD offer communities and VA medical facilities ways to assist homeless Veterans with housing and services. Program designs are diverse, ranging from transitional housing projects and apartment-style transitional housing to service centers offering outreach and supportive services. Trilogy Federal provides critical support for both initiatives by performing financial and operational fitness audit (FOFA) reviews in coordination with the Office of Business Oversight (OBO) for over 75 grantee locations, ensuring that they’re run responsibly and sustainably for the program duration. Trilogy also identifies inconsistencies, develops robust risk assessment tools, and identifies areas of improvement to allow for more efficient financial management of each site.
Approach
Using proven and comprehensive project management procedures, Trilogy works through each FOFA methodically, from kickoff and trainings to onsite evaluations to follow-through on recommended action plans. Each step of the process is conducted with a goal of exceptional service and measurable results.
Results
To date, Trilogy has performed over 200 financial and operational fitness audits across the continental United States and assisted grantee locations in understanding and implementing report information to best serve Veterans, their families, and their communities.
VA Grant Per Diem (GPD) and Supportive Services for Veteran Families (SSVF) Financial and Operational Grantee Audits
Overview
Both the SSVF and GPD offer communities and VA medical facilities ways to assist homeless Veterans with housing and services. Program designs are diverse, ranging from transitional housing projects and apartment-style transitional housing to service centers offering outreach and supportive services. Trilogy Federal provides critical support for both initiatives by performing financial and operational fitness audit (FOFA) reviews in coordination with the Office of Business Oversight (OBO) for over 75 grantee locations, ensuring that they’re run responsibly and sustainably for the program duration. Trilogy also identifies inconsistencies, develops robust risk assessment tools, and identifies areas of improvement to allow for more efficient financial management of each site.
Approach
Using proven and comprehensive project management procedures, Trilogy works through each FOFA methodically, from kickoff and trainings to onsite evaluations to follow-through on recommended action plans. Each step of the process is conducted with a goal of exceptional service and measurable results.
Results
To date, Trilogy has performed over 200 financial and operational fitness audits across the continental United States and assisted grantee locations in understanding and implementing report information to best serve Veterans, their families, and their communities.