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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
-
Vulnerabilities Remain in Medicare Hospital Outlier Payments
17-A-07-175.02We recommend that CMS determine whether the cost reports that had exceeded the 3-year reopening limit may be reopened due to similar fault and, if so, work with the Medicare contractors to reopen them.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/05/2022
- Legislative Related
- No
17-A-07-175.03We recommend that CMS ensure that the Medicare contractors review all cost reports submitted since the end of the audit periods in our previous reviews and ensure that those whose outlier payments qualified for reconciliation are correctly identified, referred, and reconciled in accordance with Federal guidelines.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/05/2022
- Legislative Related
- No
17-A-07-175.04We recommend that CMS maintain a system that identifies and tracks all cost reports that Medicare contractors have referred for reconciliation and that recalculates outlier payments on the basis of claim submissions made by hospitals.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/27/2023
- Legislative Related
- No
-
Drug Supply Chain Security: Wholesalers Exchange Most Tracing Information
17-E-05-038.02FDA should provide technical assistance regarding exempt products.- Status
- Closed Implemented
- Responsible Agency
- FDA
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/24/2022
- Legislative Related
- No
-
New York State Improperly Claimed Medicaid Reimbursement for Some Managed Long-Term Care Payments
17-A-02-170.02We recommend that DOH ensure that future contracts with MLTC plans include provisions that allow the State agency to recover payments when plans do not comply with contract requirements. This measure could have saved the Medicaid program approximately $1.4 billion ($717 million Federal share) during SFY 2014.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $717,473,637
- Last Update Received
- 01/22/2018
- Next Update Expected
- 09/11/2022
- Legislative Related
- No
-
Companion Data Services, LLC, Overstated Its Medicare Segment Pension Assets
17-A-07-165.01We recommend that CDS decrease its Medicare segment pension assets as of January 1, 2013 by $117,880 and recognize $10,430,248 as the CDS Medicare segment pension assets.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/03/2022
- Legislative Related
- No
-
Texas Improperly Received Medicaid Reimbursement for School-Based Health Services
17-A-06-152.01We recommended that the State agency refund to the Federal Government the $18,925,853 Federal share of unallowable reimbursement that was claimed for the Medicaid SHARS program because the random moments were coded incorrectly.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $18,925,853
- Last Update Received
- 09/10/2020
- Next Update Expected
- 08/25/2022
- Legislative Related
- No
-
Maine Did Not Comply With Federal and State Requirements for Critical Incidents Involving Medicaid Beneficiaries With Developmental Disabilities
17-A-01-149.02We recommend that the State agency fully implement its own regulations regarding the reporting and monitoring of critical incidents involving Medicaid beneficiaries with developmental disabilities residing in community residences. Specifically, we recommend that the State agency work with community-based providers to ensure that administrative reviews are conducted and reported appropriately.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 01/11/2023
- Legislative Related
- No
-
Oklahoma Did Not Adequately Oversee Its Medicaid Nonemergency Medical Transportation Program
17-A-06-144.01We recommend that the State agency improve its oversight and monitoring of its Medicaid NEMT brokerage program by requiring that LogistiCare strengthen its procedures to ensure that (1) transport personnel are licensed and qualified, (2) NEMT services are adequately documented, (3) vehicles used to transport Medicaid beneficiaries meet State requirements (4) beneficiaries receive Medicaid-eligible medical services on the date of transportation, and (5) NEMT services are provided.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
17-A-06-144.02We recommend the State agency ensure that managed care contracts with the transportation broker contain provisions that (1) consider improper claims to the transportation broker when developing future capitated rates paid by the State agency and (2) provide a means for the State agency to recoup funds from the transportation broker when contract provisions and State requirements are not met—a measure that, if incorporated, could result in cost savings for the Medicaid program.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
-
OHRP Generally Conducted Its Compliance Activities Independently, But Changes Would Strengthen Its Independence
17-E-01-028.01HHS should address factors that may limit OHRP's ability to operate independently.- Status
- Open Unimplemented
- Responsible Agency
- OASH
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 01/25/2019
- Legislative Related
- No
17-E-01-028.02OHRP should post the following on its website: (a) a description of its approach to oversight and (b) data (in aggregate) on the full array of its compliance activities.- Status
- Closed Implemented
- Responsible Agency
- OASH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/12/2024
- Legislative Related
- No
-
Some Hospitals in Medicare Jurisdiction E Claimed Residents as More Than One Full-Time Equivalent
17-A-02-141.01We recommend that Noridian recover $434,531 in excess Medicare GME reimbursement paid to 36 hospitals in MAC Jurisdiction E.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $434,531
- Last Update Received
- 10/09/2024
- Next Update Expected
- 04/10/2025
- Legislative Related
- No
-
Some Hospitals in Medicare Jurisdiction F Claimed Residents as More Than One Full-Time Equivalent
17-A-02-142.01We recommend that Noridian recover $365,387 in excess Medicare GME reimbursement paid to 21 hospitals in MAC Jurisdiction F.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $365,387
- Last Update Received
- -
- Closed Date
- 12/29/2022
- Legislative Related
- No
-
First Coast Service Options, Inc., Understated Its Medicare Segment and Overstated Its Other Segment Allocable Postretirement Benefit Costs
17-A-07-135.01We recommend that FCSO increase the Medicare segment PRB costs used to calculate its indirect cost rates by $50,387 for CYs 2008 through 2012.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/03/2022
- Legislative Related
- No
17-A-07-135.02We recommend that FCSO decrease the Other segment PRB costs used to calculate its indirect cost rates by $3,357,884 for CYs 2008 through 2012.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/03/2022
- Legislative Related
- No
-
First Coast Service Options, Inc., Overstated Its Medicare Segment Postretirement Benefit Assets
17-A-07-133.01We recommend that FCSO decrease its Medicare segment PRB assets by $4,997,091 as of January 1, 2013.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/03/2022
- Legislative Related
- No
-
Medicare Could Save Millions by Eliminating the Lump-Sum Purchase Option for All Power Mobility Devices
17-A-05-119.01We recommend that CMS seek legislation to eliminate the lump-sum payment option for all PMDs. If such legislation had been in place during CYs 2011 through 2014, Medicare could have saved at least an additional $10,245,539.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 07/08/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
-
HHS Did Not Identify and Report Antideficiency Act Violations
17-A-03-118.01We recommend that the PSC work with the HHS Office of the Secretary to report Antideficiency Act obligation violations totaling $20,256,755.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Overdue
- Potential Savings
- $20,256,755
- Last Update Received
- -
- Next Update Expected
- 05/12/2022
- Legislative Related
- No
17-A-03-118.02We recommend that the PSC work with the HHS Office of the Secretary to report Antideficiency Act expenditure violations totaling $29,188,270.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Overdue
- Potential Savings
- $29,188,270
- Last Update Received
- -
- Next Update Expected
- 05/12/2022
- Legislative Related
- No
17-A-03-118.03We recommend that the PSC collaborate with ASFR to identify changes to UFMS to ensure that contract expenditures for each program year are paid using the appropriate program year obligations.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/12/2022
- Legislative Related
- No
17-A-03-118.04We recommend that the PSC use “no cost” contract extensions for severable services contracts only when they do not extend the period of performance for a program year to more than 12 months.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 01/22/2024
- Next Update Expected
- 07/24/2024
- Legislative Related
- No
17-A-03-118.05We recommend that the PSC use product/service codes that accurately reflect the contract statement of work.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/12/2022
- Legislative Related
- No
-
California Incorrectly Claimed Additional Medicaid Funding Authorized Under the Recovery Act When Reclaiming Overpayments Made to Bankrupt or Out-of-Business Providers
17-A-09-102.02We recommend that the State agency ensure that it uses the FMAPs in effect when the original overpayments were made and refunded when claiming Federal reimbursement for uncollectible overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/08/2023
- Legislative Related
- No
-
New Jersey Claimed Medicaid Reimbursement for Adult Partial Hospitalization Services That Did Not Comply With Federal and State Requirements
17-A-02-100.01We recommend that the State agency refund $30,744,840 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $30,744,840
- Last Update Received
- 09/27/2024
- Next Update Expected
- 04/04/2025
- Legislative Related
- No
17-A-02-100.05We recommend that the State agency review and revise payment controls to ensure the correct rates are paid for partial hospitalization services.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/04/2024
- Legislative Related
- No
17-A-02-100.06We recommend that the State agency work with CMS to identify claims outside of our audit period that were paid at an incorrect rate or for services that were not provided by a facility licensed as a hospital.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/27/2024
- Next Update Expected
- 04/04/2025
- Legislative Related
- No
-
New York Improperly Claimed Federal Medicaid Reimbursement for Partial Hospitalization Services
17-A-02-078.02We recommend that the State agency work with OMH to reinforce to partial hospitalization providers the requirements for claiming Medicaid reimbursement for partial hospitalization services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/16/2022
- Legislative Related
- No
17-A-02-078.03We recommend that the State agency instruct OMH to look for the types of noncompliance we identified in this report when it performs its licensing renewal visits.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/16/2022
- Legislative Related
- No
-
Medicare Contractors' Payments to Providers for Hospital Outpatient Dental Services Generally Did Not Comply With Medicare Requirements
17-A-06-079.01We recommend that CMS implement national edits for hospital outpatient dental services.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 09/01/2022
- Legislative Related
- No
-
Nebraska Did Not Always Comply With Federal and State Requirements for Claims Submitted for the Nonemergency Transportation Program
17-A-07-077.01We recommend that the State agency refund to the Federal Government $1,911,138 (Federal share) in estimated overpayments. for NET claims that were in error and did not comply with Federal and State requirements.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,911,138
- Last Update Received
- 07/24/2017
- Next Update Expected
- 09/01/2022
- Legislative Related
- No
17-A-07-077.02We recommend that the State agency strengthen its policies and procedures to ensure that transportation services are provided only to recipients who are receiving Medicaid-covered services on the dates that they are receiving NET services; NET providers maintain records documenting that recipients are actually transported in the vehicles for all trips on the dates that NET services are rendered; NET providers maintain records to document the services provided; it does not pay NET providers or claim Federal reimbursement for non-covered transportation services; NET providers complete the required background checks on all potential drivers before permitting them to render NET services and annually thereafter, and maintain documentation of these checks; NET providers maintain records of all vehicle maintenance checks; and NET providers maintain documentation verifying that their drivers are qualified with current and valid driver's licenses.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 07/24/2017
- Next Update Expected
- 09/01/2022
- Legislative Related
- No
-
The University of California at Riverside's Pilot Payroll Certification System Did Not Provide Accountability Over Payroll Charges to Federal Awards
17-A-04-072.01We recommended that the University strengthen oversight of payroll charges to Federal awards by ensuring that, if the University returns to its prior effort-reporting system, it updates the system to adequately account for nonsponsored activities to ensure that payroll costs are properly allocated to Federal awards.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.02We recommended that the University strengthen oversight of payroll charges to Federal awards by ensuring that suitable means exist for a PI to verify that salary charges made to an award are reasonable in relation to the work performed.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.03We recommended that the University strengthen oversight of payroll charges to Federal awards by ensuring that suitable means exist to document that salary charges represent the actual work performed on a grant and not just budget estimates.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.04We recommended that the University strengthen oversight of payroll charges to Federal awards by requiring and documenting prior approval and justification for adjustments made after grant expenditures have been reported to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.05We recommended that the University strengthen oversight of payroll charges to Federal awards by requiring and documenting prior approval and justification for charging administrative and clerical salaries as direct costs.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.06We recommended that the University strengthen oversight of payroll charges to Federal awards by requiring and documenting prior approval and justification for cost transfers.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.07We recommended that the University strengthen oversight of payroll charges to Federal awards by developing payroll procedures to ensure that salaries are properly allocated and that salaries charged to all activities do not exceed 100 percent.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.08We recommended that the University strengthen oversight of payroll charges to Federal awards by following Federal requirements for supporting payroll costs claimed.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.09We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by improving restrictions for remote access.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.10We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by implementing a password setting that requires password changes periodically.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.11We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by implementing a patch management system for its desktop computers.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.12We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by implementing procedures to ensure that vendor support does not expire on the University's operating system.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No