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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
Showing 1,041–1,060 of 1,223 reports, containing 4,008 recommendations
Sorted by latest release date
-
Kentucky Misallocated Millions to Establishment Grants for a Health Insurance Marketplace
17-A-04-070.01We recommend that the State agency work with CMS to determine what portion of the $23.6 million was properly allocated in accordance with the relative benefits the establishment grants received from October 1, 2013, through April 15, 2014.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 08/02/2022
- Legislative Related
- No
17-A-04-070.02We recommend that the State agency refund $25.5 million to CMS that was misallocated to the establishment grants by not using updated, better data, or work with CMS to resolve the amount misallocated to the establishment grants, from April 16 through December 31, 2014.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $25,530,429
- Last Update Received
- -
- Next Update Expected
- 08/02/2022
- Legislative Related
- No
17-A-04-070.03We recommend that the State agency work with CMS to ensure that the $123.3 million that was allocated to the establishment grants on the basis of a flawed cost-allocation methodology from November 2010 through September 2013 was allocated correctly and refund any unallowable amount.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 08/02/2022
- Legislative Related
- No
17-A-04-070.04We recommend that the State agency work with CMS to ensure that costs claimed after our audit period were allocated correctly using updated, better data, and refund any unallowable amount.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 08/02/2022
- Legislative Related
- No
17-A-04-070.05We recommend that the State agency issue a written policy that explains how to develop and perform cost allocations on the basis of relative benefits received and to reassess and revise allocations when necessary.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 08/02/2022
- Legislative Related
- No
-
Colorado Claimed Unallowable Federal Reimbursement for Some Medicaid Physician-Administered Drugs
17-A-07-055.06We recommend that the State agency strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/20/2024
- Legislative Related
- No
-
Louisiana Did Not Always Comply With Federal and State Requirements for Claims Submitted for the Nonemergency Medical Transportation Program
17-A-06-053.03We recommend that the State agency, (i) strengthen its policies and procedures to ensure that providers, (ii) keep records that are necessary to document the services provided, (iii) provide transportation services only to beneficiaries receiving Medicaid-covered services, (iv) submit claims that match approved rates, and (v) do not submit claims for cancelled trips.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
17-A-06-053.04We recommend the State agency strengthen its controls over its process for reporting expenditures claimed for NEMT services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
-
Northside Medical Center Incorrectly Billed Medicare Inpatient Claims with Severe Malnutrition
17-A-03-052.01We recommend that the Hospital refund to the Medicare program $1,280,761 for the incorrectly coded claims.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $1,280,761
- Last Update Received
- -
- Closed Date
- 04/04/2022
- Legislative Related
- No
-
Delaware Did Not Bill Manufacturers for Some Rebates for Physician-Administered Drugs Dispensed to Enrollees of Medicaid Managed-Care Organizations
17-A-03-051.01We recommend that the State agency work with CMS to resolve the drug utilization without valid NDCs for which we were not able to determine an estimate by determining the correct NDCs and rebates due, billing manufacturers for the rebates, and refunding the Federal share of rebates collected.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
17-A-03-051.03We recommend that the State agency ensure that MCOs submit drug utilization data containing NDCs for all physician-administered drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
-
New Jersey Claimed Medicaid Adult Mental Health Partial Care Services That Were Not in Compliance With Federal and State Requirements
17-A-02-047.01We recommended that the State agency refund $94,830,718 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $94,830,718
- Last Update Received
- 09/27/2024
- Next Update Expected
- 04/02/2025
- Legislative Related
- No
-
Virginia Did Not Bill Manufacturers for Some Rebates for Physician-Administered Drugs Dispensed to Enrollees of Medicaid Managed-Care Organizations
17-A-03-043.03We recommend that the State agency ensure that MCOs submit drug utilization data containing NDCs for all physician-administered drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
-
Medicare Compliance Review of North Mississippi Medical Center for 2013 and 2014
17-A-04-039.02We recommended that the Hospital 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
- $6,807
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
-
Vulnerabilities Remain Under Medicare's 2-Midnight Hospital Policy
17-E-02-008.01CMS should conduct routine analysis of hospital billing and target for review the hospitals with high or increasing numbers of short inpatient stays that are potentially inappropriate under the 2-midnight policy.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/17/2023
- Next Update Expected
- 12/04/2024
- Legislative Related
- No
17-E-02-008.02CMS should identify and target for review the short inpatient stays that are potentially inappropriate under the 2-midnight policy.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/17/2023
- Next Update Expected
- 12/04/2024
- Legislative Related
- No
17-E-02-008.03CMS should analyze the potential impacts of counting time spent as an outpatient toward the 3-night requirement for SNF services so that beneficiaries receiving similar hospital care have similar access to these services.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 02/08/2018
- Next Update Expected
- 06/16/2019
- Legislative Related
- No
17-E-02-008.04CMS should explore ways of protecting beneficiaries in outpatient stays from paying more than they would have paid as inpatients.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/10/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
-
Medicare Compliance Review of Abbott Northwestern Hospital for 2013 and 2014
17-A-05-038.01We recommend that the Hospital refund to the Medicare contractor $8,038,356 (of which $933,991 was overpayments identified in our sample) in estimated overpayments for incorrectly billed services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $8,038,356
- Last Update Received
- -
- Closed Date
- 02/10/2022
- Legislative Related
- No
-
The Minnesota Marketplace Misallocated Federal Funds and Claimed Unallowable Costs
17-A-05-030.01We recommend that the Minnesota marketplace refund to CMS $346,095 that was misallocated to the establishment grants by not using the updated, better 2013 data, or work with CMS to resolve the amounts misallocated to the establishment grants.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $346,095
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
17-A-05-030.02We recommend that the Minnesota marketplace refund to CMS $933,582 consisting of $929,582 that was paid for additional marketing work performed without a contract amendment.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $929,582
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
17-A-05-030.03We recommend that the Minnesota marketplace refund to CMS $4,000 that was a duplicate payment.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $4,000
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
17-A-05-030.04We recommend that the Minnesota marketplace work with CMS to ensure that costs we did not review for the audit period and costs claimed after our audit period are allocated correctly using updated cost allocation methodology.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
17-A-05-030.05We recommend that the Minnesota marketplace implement internal controls that ensure the application of updated, better data to properly allocate costs and allocation of costs for all allocable project components.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
17-A-05-030.06We recommend that the Minnesota marketplace strengthen senior management oversight to ensure that additional contract work is not performed before an amendment is in place.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
17-A-05-030.07We recommend that the Minnesota marketplace implement internal controls to ensure proper prepayment review of invoices.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
17-A-05-030.08We recommend that the Minnesota marketplace create a complete and accurate inventory record, develop procedures to ensure that it maintains complete and accurate inventory records for equipment purchased with establishment grant funds, and conduct a physical inventory at least biennially.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/23/2022
- Legislative Related
- No
-
New York Misallocated Costs to Establishment Grants for a Health Insurance Marketplace
17-A-02-028.01We recommend that the State agency amend its CAP for the period August 2011 through March 2014 and either refund $93,393,879 to CMS that was allocated to the establishment grants using a methodology that included a material defect or work with CMS to determine the appropriate allocation to the establishment grants.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $93,393,879
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
17-A-02-028.02We recommend that the State agency refund to CMS $55,261,734, consisting of $49,493,613 that was misallocated to the establishment grants by not using updated, better data and $5,768,121 that was misallocated to the establishment grants for in-person enrollment assistance costs that also benefited Medicaid, or work with CMS to resolve the amounts misallocated to the establishment grants.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $55,261,734
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
17-A-02-028.03We recommend that the State agency refund to CMS $998,899 for costs that were incurred after the funding period had ended on an establishment grant.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $998,899
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
17-A-02-028.04We recommend that the State agency work with CMS to ensure that costs claimed after our audit period are allocated correctly using an updated cost allocation methodology.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
17-A-02-028.05We recommend that the State agency amend the CAP and the Advance Planning Documents for the period April 1 through December 31, 2014, to reflect the updated cost allocation methodology.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
17-A-02-028.06We recommend that the State agency develop a written policy that explains how to perform cost allocations and emphasizes the necessity to use updated, better data when available.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
17-A-02-028.07We recommend that the State agency ensure application of updated, better data to properly allocate costs and proper allocation of costs for all allocable project components.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
17-A-02-028.08We recommend that the State agency follow established procedures to ensure that only costs resulting from obligations of the funding period are claimed for Federal reimbursement.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 06/30/2022
- Legislative Related
- No
-
North Carolina Improperly Claimed Federal Reimbursement for Some Medicaid Nonemergency Transportation Services
17-A-04-027.01We recommended that the State agency refund $12,011,228 to the Federal Government for unallowable NEMT services identified in our sample.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $12,011,228
- Last Update Received
- -
- Closed Date
- 04/13/2022
- Legislative Related
- No
17-A-04-027.02We recommended that the State agency refund $3,121,544 to the Federal Government for the additional Federal reimbursement received for NEMT expenditures improperly claimed at the FMAP rate.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $3,121,544
- Last Update Received
- -
- Closed Date
- 04/13/2022
- Legislative Related
- No
-
Wisconsin Physicians Service Insurance Corporation Did Not Properly Settle Indiana Medicare Disproportionate Share Hospital Cost Report Payments
17-A-07-020.01We recommend that WPS revise the finalized Medicare cost report settlements to recover $6,110,557 in Medicare DSH overpayments from the 48 selected Indiana providers and refund that amount to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $6,110,557
- Last Update Received
- -
- Closed Date
- 12/14/2021
- Legislative Related
- No
-
New York Made Some Incorrect Medicaid Electronic Health Record Incentive Payments
17-A-02-010.03We recommend that the State agency review the incentive payment calculations for the hospitals not included in the 30 we reviewed to determine whether payment adjustments are needed, and refund any overpayments identified.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/16/2022
- Legislative Related
- No
-
Indian Health Service Hospitals: More Monitoring Needed to Ensure Quality Care
17-E-06-001.01IHS should implement a quality-focused compliance program to support Federal requirements for health care programs.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/25/2023
- Next Update Expected
- 11/06/2024
- Legislative Related
- No
17-E-06-001.02IHS should establish standards and expectations for how Area Offices/ Governing Boards oversee and monitor hospitals and monitor adherence to those standards.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/06/2023
- Legislative Related
- No
17-E-06-001.03IHS should continue to seek new meaningful ways to monitor hospital quality through the use of outcomes and/or process measures.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/25/2023
- Next Update Expected
- 11/06/2024
- Legislative Related
- No
17-E-06-001.04IHS should continue to invest in training for hospital administration and staff, and assess the value and effectiveness of training efforts.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/06/2023
- Legislative Related
- No
17-E-06-001.05CMS should assist IHS in its oversight efforts by conducting more frequent surveys of hospitals, informing IHS leadership of deficiency citations, and continuing to provide technical assistance and training.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 04/08/2019
- Next Update Expected
- 04/06/2020
- Legislative Related
- No
-
Indian Health Service Hospitals: Longstanding Challenges Warrant Focused Attention to Support Quality Care
17-E-06-002.02IHS should conduct a needs assessment culminating in an agencywide strategic plan with actionable initiatives and target dates.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/25/2023
- Legislative Related
- No
-
Not All Internal Controls Implemented by CDC Were Effective in Ensuring That World Trade Center Health Program Pharmacy and Medical Claims Were Paid According to Federal Requirements
16-A-02-219.01We recommend that CDC establish a procedure for collecting and transmitting NY Metro area members' prescription drug insurance coverage information to PBMs for benefits coordination.- Status
- Closed Implemented
- Responsible Agency
- CDC
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/25/2022
- Legislative Related
- No
-
California Made Incorrect Medicaid Electronic Health Record Incentive Payments to Hospitals
16-A-09-215.03We recommend that the State agency review the calculations for the hospitals not included in the 64 we reviewed to determine whether payment adjustments are needed and refund to the Federal Government any overpayments identified.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $5,650,820
- Last Update Received
- -
- Closed Date
- 04/14/2022
- Legislative Related
- No
-
Vermont Did Not Properly Allocate Millions to Establishment Grants for a Health Insurance Marketplace
16-A-01-213.01We recommend that the State agency amend its CAP for July 2012 through September 2013 and either refund $10.5 million to CMS that was allocated to the establishment grants using a methodology that included a material defect or work with CMS to determine the appropriate allocation to the establishment grants.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $10,506,676
- Last Update Received
- -
- Next Update Expected
- 09/23/2022
- Legislative Related
- No
16-A-01-213.02We recommend that the State agency use the actual enrollment data for April through September 2014 to determine the appropriate allocation to the establishment grants, work with CMS to determine what portion of $13.9 million was properly allocated to the establishment grants, and refund any portion that was not properly allocated.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 09/23/2022
- Legislative Related
- No
16-A-01-213.03We recommend that the State agency reduce establishment grant drawdowns after our audit period or refund $736,330 to CMS that was overdrawn in establishment grants as of September 30, 2014.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $736,330
- Last Update Received
- -
- Next Update Expected
- 09/23/2022
- Legislative Related
- No
16-A-01-213.04We recommend that the State agency develop policies and procedures that explain how to develop a CAP based on the relative benefits received and when to reassess and revise the CAP and related allocations on a retroactive or prospective basis.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 09/23/2022
- Legislative Related
- No
16-A-01-213.05We recommend that the State agency ensure that procedures are in place and the updated policies are followed for the reconciliation of reported grant expenditures and drawdowns to cumulative actual spending.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 09/23/2022
- Legislative Related
- No