A TCA is an instance of noncompliance with statutory, regulatory, or administrative requirements. There is no expectation for TCAs to affect the disability determination or the period of disability, but non-compliant policy case actions must be corrected. TCAs are:

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  Identified during the review process, but not covered by the formal group I or group II deficiency definitions; or

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  Identified in a non-sample case, regardless of whether the group I or group II deficiency definitions cover the incorrect action.

A substantive TCA alters some element related to the conclusion in the case. Substantive TCAs include the regulation basis code TCA and incorrect actions in a non-sample case where the group I or group II deficiency definitions cover the incorrect action.

See QR 04440.231 for definitions, handling, and correction of substantive TCAs.

A non-substantive TCA does not have an impact on the conclusion of the determination.

Types of non-substantive TCAs include, but are not limited to:

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  12-month medical evidence of record (MER)

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  Diary entry

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  Medical or vocational documentation

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  Notice

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  Determination form

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  Medical assessment form

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  Un-imaged disability determination explanation (DDE)

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  Mental impairment case

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  Unsigned consultative exam (CE)

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  Capability development

See QR 04440.232 for definitions, handling, and correction of non-substantive TCAs.

Regardless of whether the TCA is substantive or non-substantive, both types MUST be corrected.