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CIRCLE HEALTH SERVICESNon-Profit

EIN: 237078501

UEI: W4TXPPQNK4F5

Audit also covers 4 related EINs: 200754018, 237084455, 340733131, 341657978 · unlinked EINs have no separate FAC filing

Audited by: RSM US LLP

Oversight agency: 93 [Department of Health and Human Services]

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Data as of September 7, 2026

CIRCLE HEALTH SERVICES12 audit years8 findings
12
Audit Years
8
Total Findings
0
Repeat Findings
$26.1M
Federal Awards Expended (FY 2025)

FY 2025-12-31

LOW-RISK AUDITEE$26,125,787 federal awards expendedNo findings recorded this year

FY 2024-12-31

LOW-RISK AUDITEE$27,069,421 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 17, 2025 — management decision was due December 17, 2025.

FY 2023-12-31

LOW-RISK AUDITEE$27,886,951 federal awards expended

FAC accepted this audit on June 3, 2024 — management decision was due December 3, 2024.

2023-001
Subrecipient Monitoring
SIGNIFICANT DEFICIENCY

The Organization was not able to provide executed agreements with its subrecipients covering the period under audit that meet the requirements of Section 200.332 of the Uniform Guidance. Cause: Management indicated that the existing subaward agreements, which do not cover the year ended December 31, 2023, were not updated due to an oversight attributed to personnel vacancies. Effect or potential effect: Noncompliance with Section 200.332 of the Uniform Guidance could result in misunderstanding in program compliance requirements. Questioned cost: not applicable. Context: The Organization was not able to provide executed agreements that cover the audit period for the two subawards made under this program. Recommendation: We recommend that the Organization update and execute agreements with its subrecipients that contains all the required elements of Section 200.332 of the Uniform Guidance. Views of responsible officials: The Organization concurs with this finding. See page 40 for corrective action plan.

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Finding 2023-001 – Reporting Identification of federal program: Assistance Listing No. 93.558 – Temporary Assistance for Needy Families. Criteria or specific requirement: Section 200.332 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides the requirements for pass-through entities. A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(2); all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition: The Organization was not able to provide executed agreements with its subrecipients covering the period under audit that meet the requirements of Section 200.332 of the Uniform Guidance. Cause: Management indicated that the existing subaward agreements, which do not cover the year ended December 31, 2023, were not updated due to an oversight attributed to personnel vacancies. Effect or potential effect: Noncompliance with Section 200.332 of the Uniform Guidance could result in misunderstanding in program compliance requirements. Questioned cost: not applicable. Context: The Organization was not able to provide executed agreements that cover the audit period for the two subawards made under this program. Recommendation: We recommend that the Organization update and execute agreements with its subrecipients that contains all the required elements of Section 200.332 of the Uniform Guidance. Views of responsible officials: The Organization concurs with this finding. See page 40 for corrective action plan.

Corrective Action Plan

Circle Health acknowledges and agrees with this finding. We did have contracts in place with subrecipients, but they were outdated. Both program and finance staff work closely with subrecipients and ensure that they are aware of the grant requirements, reporting requirements, allowable costs, etc. Subrecipient monitoring is performed on a regular basis via review of submitted invoices, programmatic meetings and performance reviews. We will create new contracts and have all outstanding, unsigned agreements signed. We will maintain a checklist of due dates for all subrecipient agreements and review periodically throughout the year.

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FY 2022-12-31

LOW-RISK AUDITEE$29,431,810 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 11, 2023 — management decision was due January 11, 2024.

FY 2021-12-31

$23,403,231 federal awards expended

FAC accepted this audit on June 23, 2022 — management decision was due December 23, 2022.

2021-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The internal control environment in place did not ensure that the Provider Relief Fund reports were accurate prior to submission resulting in errors. In addition, we could not corroborate that the report was reviewed by an individual independent of the individual who prepared the report prior to submission. Cause: Management indicated that the reason for the misstatement was that the reports that were utilized to populate the quarterly information were not reconciled to the audited trial balance resulting in errors. In addition, the error was not detected during the secondary review of the report. Effect or potential effect: For The Centers for Families and Children, the actual revenue reported for 2019 was misstated in total by $1.3 million and also misstated by quarter. It appears that a majority of the misstatement related to the second quarter. The actual revenue reported for 2020 was misstated by $4,003 in total and was misstated for each quarter. The actual revenue reported for 2021 was misstated by $88,830 in total, and as a result, was misstated by quarter. Questioned costs:: Not applicable Context: The information on the report submitted was incorrect, however, the misstatements did not result in The Centers for Families and Children being unable to justify lost revenue based on an approved methodology. Recommendation: We recommend that policies and procedures be implemented to ensure that processes are in place to submit accurate and complete financial reports. Views of responsible officials: Management concurs with this recommendation. See page 37 for Corrective Action Plan.

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Identifying Number: 2021-001 Identification of the federal program: Assistance Listing Number 93.498, Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution. Criteria or specific requirement: The Provider Relief Fund Reporting Portal was launched on July 1, 2021. The compliance supplement has identified the calculation of lost revenues attributable to the Coronavirus as line items containing critical information on the Provider Relief Fund Report. Condition: The internal control environment in place did not ensure that the Provider Relief Fund reports were accurate prior to submission resulting in errors. In addition, we could not corroborate that the report was reviewed by an individual independent of the individual who prepared the report prior to submission. Cause: Management indicated that the reason for the misstatement was that the reports that were utilized to populate the quarterly information were not reconciled to the audited trial balance resulting in errors. In addition, the error was not detected during the secondary review of the report. Effect or potential effect: For The Centers for Families and Children, the actual revenue reported for 2019 was misstated in total by $1.3 million and also misstated by quarter. It appears that a majority of the misstatement related to the second quarter. The actual revenue reported for 2020 was misstated by $4,003 in total and was misstated for each quarter. The actual revenue reported for 2021 was misstated by $88,830 in total, and as a result, was misstated by quarter. Questioned costs:: Not applicable Context: The information on the report submitted was incorrect, however, the misstatements did not result in The Centers for Families and Children being unable to justify lost revenue based on an approved methodology. Recommendation: We recommend that policies and procedures be implemented to ensure that processes are in place to submit accurate and complete financial reports. Views of responsible officials: Management concurs with this recommendation. See page 37 for Corrective Action Plan.

Corrective Action Plan

Identifying Number: 2021-001 Identification of the federal program: Assistance Listing Number 93.498, Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding: The Provider Relief Fund Reporting Portal was launched on July 1, 2021. The compliance supplement has identified the calculation of lost revenues attributable to the Coronavirus as line items containing critical information on the Provider Relief Fund Report. The internal control environment in place did not ensure that the Provider Relief Fund reports were accurate prior to submission resulting in errors. In addition, we could not corroborate that the report was reviewed by an individual independent of the individual who prepared the report prior to submission. Corrective Actions Taken or Planned: Circle Health acknowledges and agrees with this finding. The revenue amounts reported in the Provider Relief Fund Reporting Portal for 2019-2021 were misstated. The result of this error is that the base year revenue was understated, so the error did not impact the organization?s ability to demonstrate lost revenue in years 2020 or 2021. The organization is still eligible to receive and accept Provider Relief Funds in the amount of $439,629 The process for obtaining and reporting the financial information to HRSA via the Provider Relief Fund Reporting Portal was verbally discussed and approved by the Chief Financial Officer. However, the review procedures that were in place at the time of report submission did not catch this error In an effort to correct these errors, the Organization contacted HRSA. The response we received is that the Organizations is unable to change the report once submitted, but that HRSA would contact the organization if they had any questions. In order to avoid future errors, any financial reports that are submitted to external sources will be reviewed for accuracy and completeness, and the reports will be reconciled to the amounts reported in the general ledger independent of the individual who prepared the report. Contact person: Christine Gambatese Anticipated completion date: June 10, 2022

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FY 2020-12-31

LOW-RISK AUDITEE$23,087,827 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 17, 2021 — management decision was due May 17, 2022.

FY 2019-12-31

$19,671,514 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 6, 2020 — management decision was due January 6, 2021.

FY 2018-12-31

$17,769,277 federal awards expended

FAC accepted this audit on May 1, 2019 — management decision was due November 1, 2019.

2018-001
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-002
Eligibility
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-003
Reporting
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-12-31

$15,791,551 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 29, 2018 — management decision was due October 29, 2018.

FY 2017-10-31

$1,097,871 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 26, 2018 — management decision was due October 26, 2018.

FY 2017-06-30

$1,721,545 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 26, 2018 — management decision was due September 26, 2018.

FY 2016-06-30

$1,410,885 federal awards expended

FAC accepted this audit on May 1, 2017 — management decision was due November 1, 2017.

2016-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-002
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-003
Reporting
MATERIAL WEAKNESSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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