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Recommendations Tracker
HHS-OIG provides independent and objective oversight that promotes economy, efficiency, and effectiveness in HHS programs and operations. To drive this positive change, we produce reports and identify recommendations for improvement. We have developed this public-facing page for tracking all of our open recommendations.
Use the “Top Unimplemented” View below to read OIG’s Top Unimplemented Recommendations—a subset that we think, if implemented, would have the most impact (learn more). Notable differences from our previous Top Unimplemented Recommendations report include:
- The list is comprised of individual recommendations from OIG reports, not rolled up by topic.
- No arbitrary cap is imposed on the number of recommendations included.
- Status updates as recommendations are implemented.
Summary of All Recommendations
Updated Monthly · Last updated on November 15, 2024
1,310
Unimplemented
recommendations
$270.4B
Potential savingsfrom unimplemented recommendations
2,698
Implemented and Closed
recommendations since FY 2017
Views
OIG Recommendations Grouped by Report
-
Noridian Healthcare Solutions, LLC, Did Not Claim Allowable Medicare Nonqualified Costs
20-A-07-032.01We recommend that Noridian revise its FACPs for FYs 2011-2013 to increase its Medicare nonqualified costs by $103,072.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/07/2020
- Legislative Related
- No
-
Cahaba Government Benefits Administrators, LLC, Overstated Its Medicare Segment Pension Assets as of January 1, 2017
20-A-07-029.01We recommend that Cahaba GBA decrease the Medicare segment pension assets by $2,724 and recognize $14,771,220 as the Medicare segment pension assets as of January 1, 2017.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/07/2020
- Legislative Related
- No
-
Registered Nurses Did Not Always Visit Medicare Beneficiaries' Homes At Least Once Every 14 Days To Assess The Quality of Care and Services Provided by Hospice Aides
20-A-09-028.01We recommend that the Centers for Medicare & Medicaid Services promote hospices' compliance with the condition-of-participation standard that requires registered nurses to visit hospice beneficiaries' homes at least once every 14 days to assess the quality of care and services provided by hospice aides, which could include working with State survey agencies and accreditation organizations to increase emphasis on oversight of this requirement; educating hospices about the requirements associated with this standard; and making this standard a quality measure.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/26/2021
- Legislative Related
- No
20-A-09-028.02We recommend that the Centers for Medicare & Medicaid Services take action to ensure that all registered nurses' supervisory visits of hospice aides are documented in accordance with applicable CMS regulations and interpretive guidelines.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/26/2021
- Legislative Related
- No
-
California Should Improve Its Oversight of Selected Nursing Homes' Compliance With Federal Requirements for Life Safety and Emergency Preparedness
20-A-09-026.01We recommend that the California Department of Public Health follow up with the 19 nursing homes to ensure that corrective actions have been taken regarding the life safety and emergency preparedness deficiencies identified in this report.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/10/2020
- Legislative Related
- No
20-A-09-026.02We recommend that the California Department of Public Health conduct more frequent site surveys at nursing homes to follow up on deficiencies.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/16/2021
- Legislative Related
- No
20-A-09-026.03We recommend that the California Department of Public Health ensure that all surveyors consistently enforce CMS requirements.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/10/2020
- Legislative Related
- No
20-A-09-026.04We recommend that the California Department of Public Health work with CMS to develop life safety training for nursing home staff.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/10/2020
- Legislative Related
- No
-
Highlands of Little Rock West Markham Holdings, LLC: Audit of Documentation of Therapy Resource Utilization Groups
20-A-06-025.01We recommend that the skilled nursing facility at Highlands of Little Rock West Markham refund the $25,494 in questioned costs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $25,494
- Last Update Received
- -
- Closed Date
- 04/02/2020
- Legislative Related
- No
20-A-06-025.02We recommend that the skilled nursing facility at Highlands of Little Rock West Markham educate staff to only include skilled minutes for MDS purposes.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/06/2020
- Legislative Related
- No
-
New Jersey Improperly Claimed Tens of Millions for Medicaid School-Based Administrative Costs Based on Random Moment Sampling That Did Not Meet Federal Requirements
20-A-02-024.01We recommend that the New Jersey Department of Human Services refund $63,786,406 in Federal Medicaid payments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $63,786,406
- Last Update Received
- 09/26/2024
- Next Update Expected
- 03/27/2025
- Legislative Related
- No
20-A-02-024.02We recommend that the New Jersey Department of Human Services revise its random moment sampling to comply with Federal requirements for statistical sampling, including maintaining sample documentation; its implementation plan; CMS guidance on random moment sampling; and its assurances to CMS concerning the design and operation of random moment time studies.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/26/2024
- Next Update Expected
- 03/27/2025
- Legislative Related
- No
-
The University of Minnesota Complied With Federal Requirements To Perform Risk Assessments and Monitor Subrecipients
20-A-05-023.01We recommend that the University of Minnesota refund $1,924 to NIH for unallowable costs claimed.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- $1,924
- Last Update Received
- -
- Closed Date
- 10/06/2022
- Legislative Related
- No
-
Medicare Made Hundreds of Thousands of Dollars in Overpayments for Chronic Care Management Services
20-A-07-022.01We recommend that the Centers for Medicare & Medicaid Services recoup $640,452 from providers, and instruct providers to refund overcharges totaling up to $173,495 to beneficiaries, consisting of $436,877 in overpayments to providers that billed for the same CCM services for the same beneficiaries and up to $121,573 in overcharges to these beneficiaries; and $203,575 in overpayments to providers that billed for both CCM services and overlapping care management services for the same beneficiaries and up to $51,922 in overcharges to these beneficiaries.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $640,452
- Last Update Received
- -
- Closed Date
- 04/27/2020
- Legislative Related
- No
20-A-07-022.02We recommend that the Centers for Medicare & Medicaid Services review the 37,124 outpatient claims totaling $1,162,562 in potential overpayments to determine whether the outpatient facilities met the requirement to bill for CCM services and recoup any overpayments from outpatient facilities and instruct the outpatient facilities to refund corresponding overcharges to beneficiaries.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,162,562
- Last Update Received
- -
- Next Update Expected
- Legislative Related
- No
20-A-07-022.03We recommend that the Centers for Medicare & Medicaid Services implement claim processing controls, including system edits, to prevent and detect overpayments for CCM services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/13/2021
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Understated Its Medicare Segment Pension Assets
20-A-07-015.01We recommend that Noridian increase the Medicare segment assets by $1,572,698 and recognize $30,224,354 as the Medicare segment pension assets as of January 1, 2016.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,572,698
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
20-A-07-015.02We recommend that Noridian establish policies and procedures to ensure compliance with Federal requirements and the pension segmentation language of the Medicare contracts.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Claimed Some Unallowable Medicare Pension CostsTitle
20-A-07-016.01We recommend that Noridian revise its FACPs for FYs 2011-2013 to reduce its claimed Medicare pension costs by $190799.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $190,799
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Claimed Some Unallowable Medicare Pension Costs Through Its Incurred Cost Proposals
20-A-07-017.01We recommend that Noridian work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare pension costs of $826668 for CYs 2009-2013.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $826,668
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Understated Its Medicare Segment Postretirement Benefit Assets
20-A-07-019.01We recommend that Noridian increase the Medicare segment PRB assets by $203,100 as of January 1, 2016.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $203,100
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Did Not Claim Some Allowable Medicare Postretirement Benefit Costs Through Its Incurred Cost Proposals
20-A-07-020.01We recommend that Noridian work with CMS to ensure that its final settlement of contract costs reflects an increase in Medicare PRB costs of $148,216 for CYs 2009-2013.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/07/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Claimed Some Unallowable Medicare Postretirement Benefit Costs
20-A-07-021.01We recommend that Noridian revise its FACPs for FYs 2011-2013 to decrease its Medicare PRB costs by $103,731.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $103,731
- Last Update Received
- -
- Closed Date
- 05/07/2020
- Legislative Related
- No
-
Medicare Improperly Paid Acute-Care Hospitals $54.4 Million for Inpatient Claims Subject to the Post-Acute-Care Transfer Policy
20-A-09-014.01Direct the Medicare contractors to recover the $54,372,337 in identified overpayments in accordance with CMS's policies and procedures.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $54,372,337
- Last Update Received
- -
- Closed Date
- 09/03/2020
- Legislative Related
- No
20-A-09-014.02Identify any claims for transfers to post-acute care in which incorrect patient discharge status codes were used, and direct the Medicare contractors to recover any overpayments after our audit period.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/10/2022
- Legislative Related
- No
20-A-09-014.03Ensure that the Medicare contractors are receiving the postpayment edit's automatic notifications of improperly billed claims and are taking action by adjusting the original inpatient claims to initiate recovery of the overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/23/2021
- Legislative Related
- No
20-A-09-014.04If all of the Medicare contractors had received the postpayment edit's automatic notifications of improperly billed claims and had properly taken action since CY2013, Medicare could have saved $70,011,503.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $70,011,503
- Last Update Received
- -
- Closed Date
- 03/23/2021
- Legislative Related
- No
-
Audit of Medicare Part D Pharmacy Fees: Geisinger Health Systems, Inc.
20-A-03-013.01We recommend that Geisinger refile its DIR reports for CYs 2013, 2014, and 2015 to report the unreported point-of-sale fees ($149,199 for CY2013, $167,798 for CY 2014, and $152,853 for 2015) received from pharmacies.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $469,850
- Last Update Received
- -
- Closed Date
- 10/31/2019
- Legislative Related
- No
-
Medicare Improperly Paid Suppliers an Estimated $92.5 Million for Inhalation Drugs
20-A-09-012.01We recommend that the Centers for Medicare & Medicaid Services instruct the durable medical equipment Medicare administrative contractors to recover $36,825 in overpayments for the 39 unallowable claim lines.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $36,825
- Last Update Received
- -
- Closed Date
- 12/13/2021
- Legislative Related
- No
20-A-09-012.02We recommend that the Centers for Medicare & Medicaid Services instruct the durable medical equipment Medicare administrative contractors to notify the 22 suppliers associated with the 39 claim lines with potential overpayments of $36,825 so that those suppliers can exercise reasonable diligence to investigate and return any identified overpayments, in accordance with the 60-day rule, and identify and track any returned overpayments as having been made in accordance with this recommendation.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/13/2021
- Legislative Related
- No
20-A-09-012.03We recommend that the Centers for Medicare & Medicaid Services work with the durable medical equipment Medicare administrative contractors to do the following, which could have saved Medicare an estimated $92,471,272 for CY 2017 expand their review of suppliers' claims to include additional inhalation drugs (e.g., those with the highest reimbursement rates).- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $92,471,272
- Last Update Received
- -
- Closed Date
- 09/10/2020
- Legislative Related
- No
20-A-09-012.04We recommend that the Centers for Medicare & Medicaid Services work with the durable medical equipment Medicare administrative contractors to do the following, which could have saved Medicare an estimated $92,471,272 for CY 2017 provide additional training to suppliers on Medicare documentation requirements for inhalation drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/10/2020
- Legislative Related
- No
20-A-09-012.05We also recommend that the Centers for Medicare & Medicaid Services work with the durable medical equipment Medicare administrative contractors to do the following, which could have saved Medicare an estimated $92,471,272 for CY 2017 identify suppliers that consistently bill for inhalation drugs that do not comply with Medicare documentation requirements, perform reviews of those suppliers, collect the amount overpaid for unallowable claims, and educate them on Medicare requirements for inhalation drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/10/2020
- Legislative Related
- No
-
Medicare Allowable Amounts for Certain Orthotic Devices Are Not Comparable With Payments Made by Select Non-Medicare Payers
20-A-05-011.01We recommend that the Centers for Medicare & Medicaid Services review Medicare allowable amounts for 161 orthotic device HCPCS codes for which Medicare and beneficiaries paid an estimated $337,547,542 more than select non-Medicare payers and adjust the allowable amounts, as appropriate, using regulations promulgated under existing legislative authority, or if the allowable amounts cannot be adjusted using regulations promulgated under existing legislative authority, seek legislative authority to align Medicare allowable amounts for these items with payments made by select non-Medicare payers.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $337,547,542
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
20-A-05-011.02We recommend that the Centers for Medicare & Medicaid Services routinely review Medicare allowable amounts for new and preexisting orthotic devices to ensure that Medicare allowable amounts are in alignment with payments made by select non-Medicare payers or pricing trends.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 07/18/2024
- Next Update Expected
- 01/18/2025
- Legislative Related
- No
-
Medicare Home Health Agency Provider Compliance Review: Angels Care Home Health
20-A-07-010.01We recommend that the Agency refund to the Medicare program the portion of the $3,808,603 in estimated overpayments received during CYs 2014 and 2015 for claims incorrectly billed that are within the reopening and recovery periods.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $3,808,603
- Last Update Received
- -
- Closed Date
- 02/12/2020
- Legislative Related
- No
20-A-07-010.02We recommend that the Agency for the remaining portion of the $3,808,603 in estimated overpayments for claims that are outside the 4-year reopening period, exercise reasonable diligence to identify and return overpayments in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/28/2020
- Legislative Related
- No
20-A-07-010.03We recommend that the Agency exercise reasonable diligence to identify and return any additional similar overpayments outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/28/2020
- Legislative Related
- No
20-A-07-010.04We recommend that the Agency strengthen its controls to ensure full compliance with Medicare requirements for billing home health services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/28/2020
- Legislative Related
- No
-
Tennessee Made Unallowable Capitation Payments for Beneficiaries Assigned Multiple Medicaid Identification Numbers
20-A-04-009.01We recommend that the Division of TennCare refund to the Federal Government $378,137 (Federal share) in overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $378,137
- Last Update Received
- -
- Closed Date
- 04/02/2020
- Legislative Related
- No
20-A-04-009.02We recommend that the Division of TennCare review capitation payments that fell outside of our audit period and refund any overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $259,090
- Last Update Received
- -
- Closed Date
- 04/02/2020
- Legislative Related
- No
20-A-04-009.03We recommend that the Division of TennCare enhance or establish new controls to ensure that no beneficiary is issued multiple Medicaid ID numbers.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/02/2020
- Legislative Related
- No