CORRECTIVE ACTION PLAN YEAR ENDED: JUNE 30, 2022 U.S. Department of Treasury Trilogy, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are d...
CORRECTIVE ACTION PLAN YEAR ENDED: JUNE 30, 2022 U.S. Department of Treasury Trilogy, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Treasury 2022-001 Allowable Costs (Allocation of payroll costs) ? Assistance Listing Number 21.027 Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated and support the distribution of the employee?s wages among specific activities or cost objectives if the employee works on more than one federal award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Trilogy has an internal control process in place regarding the review of eligible grant related expenditures. This process has been led by the Grants Compliance Team (GCT), since FY2018. The GCT is the key control mechanism through which allowable salaries and wage expenses are identified. Staff enter hours into ADP with their immediate supervisor signing off on entries and ensuring that salaries/ wages are being distributed to correct cost centers that reflect their actual worked hours and effort reporting. All salary allocations are approved by higher level program staff, HR and Finance staff. As a regular part of the grant revenue analysis for the monthly financial close, the GCT communicates with programs to verify the accuracy and reasonableness of labor allocations that directly impact our grant reimbursable expenses. Trilogy does acknowledge that a further verification of this process can be added through the following points: 1. Have budget owners (ie. Program Managers and/or Clinical Directors) certify through electronic signature the accuracy and reasonableness of labor allocations, monthly as a requirement of the grant invoicing process. 2. Monthly reassessment by GCT of internal transfers, exits and new recruits to each grant program to ensure allocations are reasonable for labor cost and efforts to support each program. While this is part of the current process, this process can, once again, be bolstered through electronic certifications/ signatures. 3. GCT will reassess each program?s allocations as we enter the budget season for grant renewals with our funding sources. While this is part of the current process, this process can, once again, be bolstered through electronic certifications/ signatures. Name(s) of the contact person(s) responsible for corrective action: Rich Adelman, Chief Financial Officer, Katrina Wright, Chief Human Resources Officer, Kyu Yup Kim, Grants Compliance Manager Planned completion date for corrective action plan: Trilogy will implement these action plans by the onset of FY2023 Q4 (April 1, 2023) If there are any questions regarding this plan, please call Rich Adelman, CFO at (773) 382-4002.