EIN: 362743287
UEI: V9WWULEWWUM5
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (41 days from today).
What is a management decision? →Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-24; H80CS00109-25 Award Period: May 1, 2024 – April 30, 2025; May 1, 2025 – April 30, 2026 Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay (42 USC 254(k)(3)(G); 42 CFR sections 51c.303(f), and (g); and 42 CFR sections 56.303(f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not apply sliding fee adjustments consistent with the sliding fee scale assigned. Questioned costs: None. Context: Twelve (12) of sixty (60) encounters had the incorrect sliding fee discount applied based on the family size and income documentation provided. For three (3) of sixty (60) encounters we could not verify if the family size and income were updated within a year of the patient visit date. Cause: This matter was initially identified during a prior audit and required the Organization to make an update to the electronic medical records software and process for obtaining the necessary sliding fee information. The Organization started its corrective action during the calendar year 2023 upon becoming aware of the matter. Although a prior corrective action plan has been implemented the matter has continued into the current year. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2024-002. Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Views of responsible officials: There is no disagreement with this finding.
Special Tests and Provisions Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not apply sliding fee adjustments consistent with the sliding fee scale assigned. Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA Health is strengthening controls over its sliding fee discount program. Effective FY26 (April 11, 2026), Epic will require entry of family size and income and will apply the appropriate discount based on the approved sliding fee schedule, reducing the risk of missing or incorrect discounts. Staff training on sliding fee policies and Epic workflows has been reinforced and will be refreshed at least quarterly. TCA Health will also conduct monthly audits of encounters to confirm required documentation is on file and discounts are applied in accordance with the sliding fee scale, and will use results to drive targeted follow-up and process improvements. We will increase the audit to include the total population vs. a sample when reviewing. Name(s) of the contact person(s) responsible for corrective action: Samantha O. Mitchell Planned completion date for corrective action plan: 9/1/26
2024-002
Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-24; H80CS00109-25 Award Period: May 1, 2024 – April 30, 2025; May 1, 2025 – April 30, 2026 Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay (42 USC 254(k)(3)(G); 42 CFR sections 51c.303(f), and (g); and 42 CFR sections 56.303(f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not apply sliding fee adjustments consistent with the sliding fee scale assigned. Questioned costs: None. Context: Twelve (12) of sixty (60) encounters had the incorrect sliding fee discount applied based on the family size and income documentation provided. For three (3) of sixty (60) encounters we could not verify if the family size and income were updated within a year of the patient visit date. Cause: This matter was initially identified during a prior audit and required the Organization to make an update to the electronic medical records software and process for obtaining the necessary sliding fee information. The Organization started its corrective action during the calendar year 2023 upon becoming aware of the matter. Although a prior corrective action plan has been implemented the matter has continued into the current year. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2024-002. Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Views of responsible officials: There is no disagreement with this finding.
Special Tests and Provisions Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not apply sliding fee adjustments consistent with the sliding fee scale assigned. Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA Health is strengthening controls over its sliding fee discount program. Effective FY26 (April 11, 2026), Epic will require entry of family size and income and will apply the appropriate discount based on the approved sliding fee schedule, reducing the risk of missing or incorrect discounts. Staff training on sliding fee policies and Epic workflows has been reinforced and will be refreshed at least quarterly. TCA Health will also conduct monthly audits of encounters to confirm required documentation is on file and discounts are applied in accordance with the sliding fee scale, and will use results to drive targeted follow-up and process improvements. We will increase the audit to include the total population vs. a sample when reviewing. Name(s) of the contact person(s) responsible for corrective action: Samantha O. Mitchell Planned completion date for corrective action plan: 9/1/26
2024-002
Allowable Costs and Activities Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-24; H80CS00109-25 Award Period: May 1, 2024 – April 30, 2025; May 1, 2025 – April 30, 2026 Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award (2 CFR 200.430(i)(1)). Condition: Payroll costs were allocated to grants in a manner inconsistent with the time and effort documentation provided. Questioned costs: none Context: One (1) of forty (40) allowable cost transactions selected for testing was related to payroll costs which were allocated to the grant in a manner inconsistent with the time and effort documentation provided. Amount allocated used a percentage less than the corresponding percentage on the time and effort documentation provided. Cause: Unknown Effect: Grants may be allocated costs in a manner which is inconsistent with the actual level of effort associated with the underlying employee. Repeat Finding: Yes, prior year finding 2024-003. Recommendation: Management should reinforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Views of responsible officials: There is no disagreement with this finding.
Allowable Costs and Activities Condition: Payroll costs were allocated to grants in a manner inconsistent with the time and effort documentation provided. Recommendation: Management should reinforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA Health is enhancing its time and effort and payroll allocation processes to ensure charges to grants align with documented effort. We are building on our monthly review process for time and effort by formalizing a review in which payroll allocation percentages are compared to signed attestations, with Finance documenting any corrections and follow-up. We are also partnering with HR to ensure all Personnel Action Forms (PAFs) include appropriate grant coding and to require an updated PAF whenever an employee’s grant funding or allocation changes. In addition, TCA Health is implementing an automated integration between ADP and Sage Intacct so that approved timesheets flow directly into payroll and grant reporting, improving accuracy and the audit trail. We will leverage the systems and limit manual entry. Name(s) of the contact person(s) responsible for corrective action: Bob Van Gilder Planned completion date for corrective action plan: 9/1/26 If the U.S. Departments above have questions regarding this plan, please call Veronica Clarke, Chief Executive Office, at 773-928-5090.
2024-003
Allowable Costs and Activities Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-24; H80CS00109-25 Award Period: May 1, 2024 – April 30, 2025; May 1, 2025 – April 30, 2026 Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award (2 CFR 200.430(i)(1)). Condition: Payroll costs were allocated to grants in a manner inconsistent with the time and effort documentation provided. Questioned costs: none Context: One (1) of forty (40) allowable cost transactions selected for testing was related to payroll costs which were allocated to the grant in a manner inconsistent with the time and effort documentation provided. Amount allocated used a percentage less than the corresponding percentage on the time and effort documentation provided. Cause: Unknown Effect: Grants may be allocated costs in a manner which is inconsistent with the actual level of effort associated with the underlying employee. Repeat Finding: Yes, prior year finding 2024-003. Recommendation: Management should reinforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Views of responsible officials: There is no disagreement with this finding.
Allowable Costs and Activities Condition: Payroll costs were allocated to grants in a manner inconsistent with the time and effort documentation provided. Recommendation: Management should reinforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA Health is enhancing its time and effort and payroll allocation processes to ensure charges to grants align with documented effort. We are building on our monthly review process for time and effort by formalizing a review in which payroll allocation percentages are compared to signed attestations, with Finance documenting any corrections and follow-up. We are also partnering with HR to ensure all Personnel Action Forms (PAFs) include appropriate grant coding and to require an updated PAF whenever an employee’s grant funding or allocation changes. In addition, TCA Health is implementing an automated integration between ADP and Sage Intacct so that approved timesheets flow directly into payroll and grant reporting, improving accuracy and the audit trail. We will leverage the systems and limit manual entry. Name(s) of the contact person(s) responsible for corrective action: Bob Van Gilder Planned completion date for corrective action plan: 9/1/26 If the U.S. Departments above have questions regarding this plan, please call Veronica Clarke, Chief Executive Office, at 773-928-5090.
2024-003
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 17, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 17, 2026, which was (215 days ago).
What is a management decision? →Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-22; H80CS00109-23 Award Period: May 1, 2023 – April 30, 2024; May 1, 2024 – April 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay (42 USC 254(k)(3)(G); 42 CFR sections 51c.303(f), and (g); and 42 CFR sections 56.303(f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not apply sliding fee adjustments consistent with the sliding fee scale assigned. Questioned costs: None. Context: • Nine (9) of sixty (60) encounters did not have family size and income documented within the billing system in order to assess sliding fee discount eligibility. Each of these encounters occurred prior to December 31, 2023. • Five (5) of sixty (60) encounters did not have family size and income documentation updated within a year of the patient visit date. Three (3) of these encounters occurred prior to December 31, 2023 and two (2) occurred subsequent to December 31, 2023. • Thirteen (13) of sixty (60) encounters received a sliding fee adjustment which was incorrect based on the sliding fee scale assigned. Seven (7) of these occurred prior to December 31, 2023 and six (6) occurred subsequent to December 31, 2023. Cause: This matter was identified during a prior audit and required the Organization to make an update to the electronic medical records software and process for obtaining the necessary sliding fee information. The Organization started its corrective action during fiscal year 2024 upon becoming aware of the matter. As a result of when this matter was first identified, corrective action was not able to occur prior to the start of the fiscal year ended June 30, 2024. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Views of responsible officials: There is no disagreement with this finding.
Recommendation: Management should continue to provide training and education to front desk staff related to the process for collecting family size and income information, along with inputting it into the electronic medical records. We also recommend enhancing any current internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA Health has addressed the Special Provisions weakness by coaching and training front desk staff members. Specifically, staff were trained in the approved sliding fee scale policy and its requirements. Worked with third-party billing company, and Athena to roll back the EMR update which contributed to ineffective application of the sliding fee in November 2023. TCA hired a full-time Patient Services Manager in 2024 to support ongoing staff training, quality assurance monitoring, and implementation of the updated EMR and registration workflows. Staff have become proficient in the collection of data from patients, properly storing and recording it in the EMR, and the calculation of the slide according to the Federal Poverty Guidelines. Lastly, the team will be updated on the latest EMR module that experienced an upgrade and taught how to effectively apply the slide. Additionally, TCA began to undergo internal audits of records ensuring that proper documentation is maintained and a patient service manager, utilizing testing template provided by the organization’s auditor. Name(s) of the contact person(s) responsible for corrective action: Samantha Oliver Mitchell, Chief Operating Officer Planned completion date for corrective action plan: June 2025
2023-002
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-22; H80CS00109-23 Award Period: May 1, 2023 – April 30, 2024; May 1, 2024 – April 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance and Immaterial Noncompliance Criteria or specific requirement: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award (2 CFR 200.430(i)(1)). Condition: Payroll costs charged to federal grants were either missing documentation related to time and effort or were allocated to grants in a manner inconsistent with the time and effort documentation provided. Questioned costs: $7,444 Context: Six (6) of forty (40) allowable cost transactions selected for testing were related to payroll costs and were missing time and effort documentation. Eight (8) of forty (40) allowable cost transactions selected for testing were related to payroll costs which were allocated to the grant in a manner inconsistent with the time and effort documentation provided. Two (2) of forty (40) allowable cost transactions selected for testing were related to payroll and contained a difference between the hours worked per the timesheet and hours paid per the payroll register. Cause: Unknown Effect: Grants may be allocated costs in a manner which is inconsistent with the actual level of effort associated with the underlying employee. Repeat Finding: No. Recommendation: Management should reenforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Views of responsible officials: There is no disagreement with this finding.
Recommendation: Management should reenforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA has changed the time and effort sheet to be less confusing for staff. Also, we can set up allocations in our payroll system which the employee and supervisor have to sign off on their time card for each payroll. Name(s) of the contact person(s) responsible for corrective action: Jeremy Runde, Controller Planned completion date for corrective action plan: June 2025
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-22; H80CS00109-23 Award Period: May 1, 2023 – April 30, 2024; May 1, 2024 – April 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: The organization did not maintain appropriate documentation to support the procurement method utilized for a contract selected for testing. Questioned costs: None Context: One (1) of five (5) procurement transactions selected for testing. Cause: The Organization did not create and maintain appropriate documentation to support the method of procurement utilized, including the consideration of an adequate number of qualified sources. Effect: Possible noncompliance with 2 CFR section 200.320(c)(1) - (3) Repeat Finding: No. Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Views of responsible officials: There is no disagreement with this finding.
Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management and finance staff will more closely monitor when non-payroll expenditures are charged to federal grants and adhere to procurement policy when over the required threshold that requires board approval over equipment, supplies, and services $10,000 and 3 written bids when over $100,000. Additionally, finance staff will seek out training from contracted third-party consultant when documenting procurement items to ensure that all documentation required is maintained. Further, the procurement policy will be reviewed on a regular basis to ensure that personnel involved in procurement are educated in regards to the policy and procedures. Name(s) of the contact person(s) responsible for corrective action: Jeremy Runde, Controller Planned completion date for corrective action plan: June 2025
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-22; H80CS00109-23 Award Period: May 1, 2023 – April 30, 2024; May 1, 2024 – April 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.305(b)(1) requires that recipients of federal funds maintain both written procedures that minimize the time elapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient, and financial management systems that meet the standards for fund control and accountability. Furthermore, 2 CFR 200.303 indicates the non-Federal entity must: (a) Establish, document and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization did not maintain timely documentation to support an independent review and approval of the drawdowns prior the drawdown occurring. Questioned costs: None Context: This condition occurred in two (2) of six (6) transactions selected for testing. Cause: Turnover in key positions within the finance department. Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet. Repeat Finding: No. Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control. Views of responsible officials: There is no disagreement with this finding.
Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA will have a Grant/Staff Account or designee prepare documentation for the drawdowns. The CEO or designee will approve drawdown documents. CFO/Controller or designee will process the drawdown and take a screenshot when completed. All approvals will be shown on the excel sheet with the drawdown information. Name(s) of the contact person(s) responsible for corrective action: Jeremy Runde, Controller Planned completion date for corrective action plan: June 2025
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 11, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 11, 2025, which was (435 days ago).
What is a management decision? →Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-21; H80CS00109-22 Award Period: May 1, 2022 – April 30, 2023; May 1, 2023 – April 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and did not assign patients a sliding fee category. Questioned costs: None. Context: Twenty-five (25) of forty (40) encounters did not have current documentation of family size and income to assess sliding fee discount eligibility, and twenty-five (25) of twenty-five (25) were not assigned a sliding fee category. Cause: This matter was identified during a prior audit and corrected during the second half of calendar year 2023. As a result of when this matter was first identified, corrective active was not able to occur prior to the year ended June 30, 2023 audit. Corrective action occurring during the second half of calendar year 2023. Effect: Patients may not be assessed a correct sliding fee discount according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2022-003. Recommendation: Management should continue to work with its third-party vendors to ensure the accuracy and completeness of the patient information within its billing software in addition to continuing to conduct internal audits of patient visits to determine all required patient information has been obtained in accordance with TCA’s policies. Views of responsible officials: There is no disagreement with this finding.
The CFO at TCA Health has addressed the Special Provisions weakness by coaching and training front desk staff members. Specifically, staff were trained in the approved sliding fee scale policy and its requirements. The COO worked with the CFO and third-party billing company, and Athena to roll back the EMR update which contributed to ineffective application of the sliding fee in November 2023. TCA hired a full time Patient Services Manager in 2024 to support ongoing staff training, quality assurance monitoring, and implementation of the updated EMR and registration workflows. Staff have become proficient in the collection of data from patients, properly storing and recording it in the EMR, and the calculation of the slide according to the Federal Poverty Guidelines. Lastly, the team will be updated on the latest EMR module that experienced an upgrade and taught how to effectively apply the slide. Additionally, TCA began to undergo internal audits of records ensuring that proper documentation is maintained and a patient service manager, utilizing testing template provided by the organization’s auditor.
2022-003
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 12, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 12, 2024, which was (616 days ago).
What is a management decision? →Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21 Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023 Type of Finding: Compliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization did not maintain documentation to show that patients had been evaluated for eligibility under its sliding fee scale policy and incorrectly calculated or applied the sliding fee scale policy based on their family size and annual income. Questioned costs: None. Context: This condition occurred in twenty-six (26) of forty (40) transactions selected for testing. Cause: Unknown. Effect: Patients may not be assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes, prior year finding 2021-005. Recommendation: Management should refine and expand its internal audits of patient visits and hold additional trainings for front desk staff to ensure they understand the appropriate steps to take, and information to obtain, for sliding fee encounters. Views of responsible officials: There is no disagreement with this finding.
The COO at TCA Health will address the Special Provisions weakness by coaching and training front desk staff members. Specifically, staff will be trained in the sliding fee scale and its requirements. Staff will become proficient in the collection of data from patients, properly storing and recording it in the EMR, and the calculation of the slide according to the Federal Poverty Guidelines. Lastly, the team will be updated on the latest EMR module that experienced an upgrade and taught how to effectively apply the slide. TCA will also assess the current staff to ensure the proper personnel is in in place.
2021-005
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21 Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The organization did not maintain documentation to support the performance of an independent review and approval of the amounts to be drawn prior the draw occurred. Questioned costs: None. Context: This condition occurred in three (3) of five (5) transactions selected for testing. Cause: Turnover in key positions within the finance department. Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet. Repeat Finding: Yes, prior year finding 2021-004. Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control. Views of responsible officials: There is no disagreement with this finding.
The COO at TCA Health will address Cash Management first, reviewing the policy and procedure to ensure it’s up to date with today’s best practices and modern standards. In doing so, TCA will review the organization chart to assess if the policy and procedure to match the personnel structure that’s currently in place. Changes will be made if necessary. Additionally, TCA has hired a third-party consulting firm that can assist with grant best practices.
2021-004
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Center Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-20; H80CS00109-21 Award Period: May 1, 2021 – April 30, 2022; May 1, 2022 – April 30, 2023 Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance § 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition: The Organization allocated payroll costs in a manner inconsistent with the personnel activity reports provided for the applicable employees and time periods selected for testing. Questioned Costs: Unknown Context: This condition occurred in four (4) of the forty (40) allowable cost transactions selected for testing within the health centers cluster major program, and represented three (3) different employees. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not consistently allocate payroll costs based on the personnel activity reports created. Cause: Turnover within the finance department contributed to needing to reallocate certain payroll costs. Repeat Finding: No. Recommendation: We recommend that the Organization allocated payroll costs to grants in a manner that is consistent with the documentation contained within the personnel activity reports. Views of responsible officials: There is no disagreement with this finding.
TCA Health will address the Allowable Costs and Activities first, by hiring additional accounting professionals both internally and as third- party consultants to support the grants management process in place at TCA. As part of that work, the third-party consultant will review the Time and Effort reporting policy and model. TCA currently feels that what the process that they utilized to allocate salary and wage expense to the grant related to this finding was allowable from a Uniform Grants Guidance perspective, however they were not compliant with their policy and will work to revise their policy to less restrictive (although still in compliance with the UGG). The iCFO will create greater monitoring of the month-end process as it relates to the allocation of payroll costs to be consistent with the personnel activity reports and the Health Center’s revised policy.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 29, 2023. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 29, 2023, which was (965 days ago).
What is a management decision? →Finding 2021-003 ? Allowable Costs and Activities Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Centers Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-19; H80CS00109-20; H8DCS36123-01; H8ECS37694-01; H8FCS41694-01 Award Period: May 1, 2020 ? April 30, 2021; May 1, 2021 ? April 30, 2022; April 1, 2020 - March 31; May 1, 2020 - April 30, 2021; April 1, 2021 ? March 31, 2023, all respectively Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Code of Federal Regulation (CFR) ? 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, management is responsible for adopting sound accounting policies and establishing and maintaining a system of internal control over compliance in order to ensure allowable costs are accurately captured and charged to federal awards in accordance with the Uniform Guidance, and appropriate and necessary supporting documentation is maintained. Condition: There were five payroll transactions selected for testing which either did not have the necessary supporting documentation to agree to payroll records or the information provided did not agree. General Disbursements Testing: Two transactions selected for testing did not have sufficient documentation to support the expenses charged to the grant. Questioned costs: Known: $135 consisting of two payroll transactions. Context: This condition occurred in seven (7) of forty (40) transactions selected for testing. Cause: Turnover in key positions within the finance department. Effect: Amounts for which the Organization reimburses itself for under the grant may be for unallowable costs or activities. Repeat Finding: No Recommendation: We recommend management provide additional training to those involved in the purchasing and payroll processes especially as it relates to federal grant reimbursement requirements and record retention and storage. Views of responsible officials: There is no disagreement with this finding.
TCA Health will address the Allowable Cost material weakness by educating staff about Federal rules and compliance regarding grant spending and allowable costs. This process will give employees the tools to be effective and knowledgeable regarding federal programs. Additionally, we will streamline our record retention and storage process to make documents readily available during audits and ensure we have adequate backup. A greater filing and organization system will alleviate many issues when tracking and producing documentation for the details of our programs. The Finance department and Human Resources will work closely together to address any discrepancies in payroll and timecards as HR will receive greater staffing. The above-listed Corrective Action Plan will be executed by the Chief Financial Officer Jeren Stepp. The estimated completion date is December 31st, 2023.
Finding 2021-004 ? Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Centers Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-19; H80CS00109-20; H8DCS36123-01; H8ECS37694-01; H8FCS41694-01 Award Period: May 1, 2020 ? April 30, 2021; May 1, 2021 ? April 30, 2022; April 1, 2020 - March 31; May 1, 2020 - April 30, 2021; April 1, 2021 ? March 31, 2023, all respectively Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: CFR ? 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The organization made seven (7) drawdowns on these grants but did not maintain documentation to support the performance of an independent review and approval of the amounts to be drawn prior the draw occurred. Questioned costs: None. Context: This condition occurred in seven (7) of seven (7) transactions selected for testing. Cause: Turnover in key positions within the finance department. Effect: Drawdowns may occur for the incorrect amount, for the wrong period and for costs that may not have been incurred as of yet. Repeat Finding: No Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control. Views of responsible officials: There is no disagreement with this finding.
The CFO at TCA Health will address Cash Management first, reviewing the policy and procedure to ensure it?s up to date with today?s best practices and modern standards. In doing so, TCA will review the organization chart to assess if the policy and procedure to match the personnel structure that?s currently in place. Changes will be made if necessary. The above-listed Corrective Action Plan will be executed by the Chief Financial Officer Jeren Stepp. The estimated completion date is December 31st, 2023.
Finding 2021-005 ? Special Provisions Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Health Centers Program Cluster Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00109-19; H80CS00109-20; H8DCS36123-01; H8ECS37694-01; H8FCS41694-01 Award Period: May 1, 2020 ? April 30, 2021; May 1, 2021 ? April 30, 2022; April 1, 2020 - March 31; May 1, 2020 - April 30, 2021; April 1, 2021 ? March 31, 2023, all respectively Type of Finding: Compliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization assigned 16 patients an incorrect sliding fee discount based on their family size and annual income Questioned costs: None. Context: This condition occurred in sixteen (16) of twenty-five (25) transactions selected for testing. Cause: Unknown. Effect: Applicants assessed are not charged according to the Organization's sliding fee scale and their ability to pay. Repeat Finding: Yes Recommendation: Management should refine and expand its internal audits of patient visits and hold additional trainings for front desk staff to ensure they understand the appropriate steps to take, and information to obtain, for sliding fee encounters. Views of responsible officials: There is no disagreement with this finding.
The CFO at TCA Health will address the Special Provisions weakness by coaching and training front desk staff members. Specifically, staff will be trained in the sliding fee scale and its requirements. Staff will become proficient in the collection of data from patients, properly storing and recording it in the EMR, and the calculation of the slide according to the Federal Poverty Guidelines. Lastly, the team will be updated on the latest EMR module that experienced an upgrade and taught how to effectively apply the slide. TCA will also assess the current staff to ensure the proper personnel is in in place. The above-listed Corrective Action Plan will be executed by the Chief Financial Officer Jeren Stepp. The estimated completion date is December 31st, 2023.
2020-002
Finding 2021-006 ? Allowable Costs and Activities Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus Relief Fund Assistance Listing Number: 21.019 Pass Through Agency: Illinois Department of Human Services Pass Through Award Number: 1FCSZG00268 Award Period: July 1, 2020 ? June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: CFR ? 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, management is responsible for adopting sound accounting policies and establishing and maintaining a system of internal control over compliance in order to ensure allowable costs are accurately captured and charged to federal awards in accordance with the Uniform Guidance, and appropriate and necessary supporting documentation is maintained. Condition: The organization inadvertently paid one program participant $80 more than they qualified for based on their hours worked. However, this excess payment was ultimately not reimbursed by the federal grant and further grant vouchers were adjusted to account for this. Questioned costs: None. Context: This condition occurred in one (1) of forty (40) transactions selected for testing. Cause: Oversight. Effect: Organization may overpay its program participants for the number of hours worked and result in unallowable costs reimbursed under the grant. Repeat Finding: No Recommendation: Management should consider implementing an additional layer of review of all checks cut prior to sending to the program participants to ensure checks match the approved timesheets. Views of responsible officials: There is no disagreement with this finding.
TCA Health will address the Allowable Costs and Activities weakness by executing greater oversight of the grant programs and accounting. The oversight will begin with a meeting with program managers to understand and create best practices for managing the tasks of the grant programs. Finance staff will execute proper GAP to ensure transactions are recorded properly. Account reconciliations will be performed regularly to identify and correct errors. The above-listed Corrective Action Plan will be executed by the Chief Financial Officer Jeren Stepp. The estimated completion date is December 31st, 2023.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 6, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 6, 2022, which was (1506 days ago).
What is a management decision? →Federal Agency: United States Department of Health and Human Services Federal Program Title: Health Centers Cluster CFDA Number: 93.224/93.527 Award Period: May 1, 2019 ? April 30, 2020; May 1, 2020 ? April 30, 2021 Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Health centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. (42 USC 254(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g)). Condition: The Organization assigned an incorrect sliding fee discount based on the patient?s family size and annual income Questioned costs: None Context: This condition occurred in four (4) of the twenty-five (25) sliding fee encounters selected for testing. Cause: Oversight and staff turnover. Effect: Patients are not charged according The Organization's sliding fee discount policy. Repeat Finding: No Recommendation: Management should continue to refine and expand its internal audits of patient visits and hold additional trainings for front desk staff. Views of responsible officials: TCA Health Inc. will implement a sliding fee program training annually for intake staff on proper intake processes. Additionally, TCA will conduct quarterly spot audits of sliding fee discount program claims to assure proper documentation. Staff who continue to struggle will be trained individually and put on performance improvement plans when necessary.
2020-002 ? Special Tests and Provisions Health Centers Cluster ? CFDA 93.224 and 93.527 Type of Finding: Compliance and Significant deficiency in internal control over compliance Condition: The Organization assigned an incorrect sliding fee discount, based on patient?s family size and annual income, to four encounters during the year. Recommendation: Management should continue to refine and expand its internal audits of patient visits and hold additional trainings for front desk and billing staff regarding the calculation and assigned for sliding fee discounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: TCA will implement a sliding fee program training annually for intake staff on proper intake processes. Additionally, TCA will conduct quarterly spot audits of sliding fee discount program claims to assure proper documentation. Staff who continue to struggle will be trained individually and put on performance improvement plans when necessary. Name(s) of the contact person(s) responsible for corrective action: Michelle Harris, Director of Finance. Planned completion date for corrective action plan: January 2022
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 13, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 13, 2021, which was (2045 days ago).
What is a management decision? →2019 ? 001 ? Allocation of Costs Federal Agency: United States Department of Agriculture Federal Program Title: Special Supplemental Nutrition Program for Women, Infants and Children (WIC) CFDA Number: 10.557 Pass-Through Agency: Illinois Department of Human Services Pass-Through Number(s): FCSXQ01103 Award Period: July 1, 2018 ? June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR ? 200.405(a) indicates a cost is allocable to a particular federal award or other cost objective if the goods or services involved are chargeable or assignable to that federal award or cost objective in accordance with relative benefits received. Furthermore 2 CFR ? 200.405(d) indicates if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: The Organization has established an allocation methodology for allocable costs based on the square footage of the building which program activities occur. It was noted that this standard allocation methodology was not consistently used during transactions selected for testing and support did not exist to justify an alternative allocation methodology. Questioned costs: None Context: This condition occurred in two (2) of forty (40) allowable cost transactions selected for testing. Cause: Oversight and staff turnover. Effect:The effect of the above condition was an under allocation of expenses to the federally funded grant as compared to the established allocation methodology based on the square footage of building space. Repeat Finding: No Recommendation: Management should continue to follow the established allocation methodology for allocable costs. In instanced where the established allocation methodology is determined to not be appropriate, documentation should be maintained to justify why an alternative methodology was utilized. Views of responsible officials: Management has established facility costs allocation method based on square footage which his consistently applied. The two occurrences were due to human error.
2019-001 Allocation of Costs TYPE OF FINDING: Significant deficiency in internal control over compliance Condition: The Organization has established an allocation methodology for allocable facility costs based on the square footage of the building which program activities occur. It was noted that this standard allocation methodology was not consistently used during transactions selected for testing. The error occurred due to temporary accounting staff applied incorrect percentage. Recommendation: Management should continue to follow the established allocation methodology for allocable facility costs. In instanced where the established allocation methodology is determined to not be appropriate, documentation should be maintained to justify why an alternative methodology was utilized. Action taken in response to finding: Management has an established facility costs allocation method based on square footage which is consistently applied. The two occurrences were due to human error. Name of the contact person responsible for corrective action: Thurman Gills, CFO Planned completion date for corrective action plan: The controls are in place as of the audit report date. If there are any questions regarding this plan, please call Thurman Gills, CFO at 773-995-6300 ext. 208.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 29, 2019. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 29, 2019, which was (2517 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2017-003
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 29, 2018. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 29, 2018, which was (2882 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2016-002
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
2016-004
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2017. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2017, which was (3246 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2015-002
GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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