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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 1,121–1,140 of 1,223 reports, containing 4,008 recommendations
Sorted by latest release date
-
The District of Columbia Claimed Unallowable Federal Reimbursement for Some Medicaid Physician-Administered Drugs
14-A-03-263.01We recommend the State Agency refund to the Federal Government $2,392,539 (Federal share) for single-source and top-20 multiple-source physician-administered drug claims that were ineligible for Federal reimbursement.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $2,392,539
- Last Update Received
- -
- Closed Date
- 11/01/2021
- Legislative Related
- No
14-A-03-263.03We recommend the State agency work with CMS to determine and refund the unallowable Federal reimbursement for physician-administered drugs claimed without NDCs after January 1, 2011.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/17/2024
- Legislative Related
- No
14-A-03-263.04We recommend the State agency ensure that its MMIS edits require valid NDCs for payment on all drug claims.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
14-A-03-263.05We recommend that the State agency improve its rebate processes to ensure that all physician-administered drug claims are submitted for rebates.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
-
Servicios Suplementarios de Salud, Inc., Improperly Claimed Medicare Reimbursement for Some Hospice Services
14-A-02-244.01We recommend that the Hospice refund $453,558 to the Federal Government.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $453,558
- Last Update Received
- -
- Closed Date
- 11/18/2019
- Legislative Related
- No
-
Virginia Improperly Claimed Federal Reimbursement for Most Reviewed Medicaid Payments to Catawba Hospital
14-A-05-220.01We recommend that the State Medicaid agency refund $17,395,647 to the Federal Government for its share of payments to Catawba for inpatient hospital services it provided to patients aged 65 or older on dates outside the regulatory gap period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $17,395,647
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
14-A-05-220.02We recommend that the State Medicaid agency work with CMS to determine whether the State Medicaid agency should refund an additional $1,212,002 to the Federal Government for its share of payments to Catawba for inpatient hospital services it provided to patients aged 65 or older on dates during the regulatory gap period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,212,002
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
14-A-05-220.03We recommend that the State Medicaid agency identify and refund the Federal share of any additional Medicaid payments to Catawba for inpatient hospital services it provided to patients aged 65 or older on dates after the audit period if neither the State Medicaid agency nor Catawba can demonstrate Catawba's compliance with Federal requirements for those services.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
14-A-05-220.04We recommend that the State Medicaid agency ensure that it claims Federal reimbursement for Medicaid payments for inpatient hospital services provided to patients aged 65 or older in IMDs only if those IMDs can demonstrate compliance with the special Medicare CoP.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
-
Virginia Improperly Claimed Federal Reimbursement for Most Reviewed Medicaid Payments to Piedmont Geriatric Hospital
14-A-05-221.01We recommend that the State Medicaid agency refund $36,903,169 to the Federal Government for its share of payments to Piedmont for inpatient hospital services it provided to patients aged 65 or older on dates outside the regulatory gap period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $36,903,169
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
14-A-05-221.02We recommend that the State Medicaid agency work with CMS to determine whether the State Medicaid agency should refund an additional $2,462,157 to the Federal Government for its share of payments to Piedmont for inpatient hospital services it provided to patients aged 65 or older on dates during the regulatory gap period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $2,462,157
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
14-A-05-221.03We recommend that the State Medicaid agency ensure that it claims Federal reimbursement for Medicaid payments for inpatient hospital services provided to patients aged 65 or older in IMDs only if those IMDs can demonstrate compliance with the special Medicare CoP.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
-
New York Claimed Nonhospital-Based Continuing Day Treatment Services That Were Not in Compliance With Federal and State Requirements
14-A-02-213.01We recommend the State agency refund $18,093,953 to the Federal government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $14,108,014
- Last Update Received
- 03/24/2024
- Next Update Expected
- 09/24/2024
- Legislative Related
- No
-
Medicare Compliance Review of University of Cincinnati Medical Center for Calendar Years 2010 and 2011
14-A-05-193.01We recommend that the Hospital refund to the Medicare contractor $9,818,296 (of which $603,267 was net overpayments identified in our sample) in estimated net overpayments for CYs 2010 and 2011 that it incorrectly billed.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $9,818,296
- Last Update Received
- -
- Closed Date
- 02/11/2022
- Legislative Related
- No
-
Vulnerabilities in Medicare's Interrupted-Stay Policy for Long-Term Care Hospitals
14-E-04-052.02CMS should conduct additional analysis to determine the extent to which financial incentives influence LTCH readmission decisions.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/18/2024
- Legislative Related
- No
-
The Medicare Contractors for Jurisdiction H Overpaid Providers for Selected Outpatient Drugs
14-A-06-174.01We recommend that Novitas recover the $3,341,188 in identified overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $3,341,188
- Last Update Received
- -
- Closed Date
- 12/03/2015
- Legislative Related
- No
-
Compounded Drugs Under Medicare Part B: Payment and Oversight
14-E-03-048.02CMS should explore the possibility of requiring providers to identify on the Part B claim the pharmacy that produced the compounded drug.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/22/2024
- Legislative Related
- No
14-E-03-048.03CMS should explore the possibility of conducting descriptive analyses of Part B claims for compounded drugs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 02/24/2022
- Next Update Expected
- 03/10/2023
- Legislative Related
- No
-
Vulnerabilities in the HHS Small Business Innovation Research Program
14-E-04-047.03HHS OpDivs should ensure compliance with SBIR eligibility requirements.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/14/2024
- Next Update Expected
- 07/02/2025
- Legislative Related
- No
14-E-04-047.04HHS OpDivs should improve procedures to check for duplicative awards.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/14/2024
- Next Update Expected
- 07/02/2025
- Legislative Related
- No
-
Medicare and Beneficiaries Could Save Billions If CMS Reduces Hospital Outpatient Department Payment Rates for Ambulatory Surgical Center-Approved Procedures to Ambulatory Surgical Center Payment Rates
14-A-05-157.01Seek legislation that would exempt the reduced expenditures as a result of lower OPPS payment rates from budget neutrality adjustments for ASC-approved procedures.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 10/03/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
14-A-05-157.02Reduce OPPS payment rates for ASC-approved procedures on beneficiaries with no-risk or low-risk clinical needs in outpatient departments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 10/03/2024
- Next Update Expected
- 05/30/2022
- Legislative Related
- No
14-A-05-157.03Develop and implement a payment strategy in which outpatient departments would continue to receive the standard OPPS payment rate for ASC-approved procedures that must be provided in an outpatient department because of a beneficiary's individual clinical needs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $15,000,000,000
- Last Update Received
- 10/03/2024
- Next Update Expected
- 05/30/2022
- Legislative Related
- No
-
Iowa Has Shifted Medicare Cost-Sharing for Dual Eligibles to the Federal Government
14-E-07-041.01CMS should seek legislative change to prevent States from using State Supplementary Payments to shift Medicare Part B premium costs for FBDEs to the Federal Government.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/07/2024
- Legislative Related
- Yes
14-E-07-041.02CMS should require States to submit more detailed eligibility information.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/07/2024
- Legislative Related
- No
-
New Jersey Claimed Excessive Medicaid Disproportionate Share Hospital Payments to Four Hospitals
14-A-02-143.01We recommend that the State agency refund $22,004,768 to the Federal Government.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $22,004,768
- Last Update Received
- -
- Closed Date
- 12/30/2021
- Legislative Related
- No
-
Update: Medicare Payments for End Stage Renal Disease Drugs
14-E-03-037.02CMS should distinguish payments in the ESRD base rate between independent and hospital-based dialysis facilities.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/22/2024
- Legislative Related
- No
-
Comparing Average Sales Prices and Average Manufacturer Prices for Medicare Part B Drugs: An Overview of 2012
14-E-03-035.02CMS should expand the price substitution policy to include HCPCS codes with partial AMP data.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/25/2024
- Legislative Related
- No
-
CMS Regularly Reviews Part C Reporting Requirements Data, But Its Followup and Use of the Data Are Limited
14-E-03-032.01CMS should determine whether outlier data values submitted by MA contracts reflect inaccurate reporting or atypical performance.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/10/2024
- Legislative Related
- No
14-E-03-032.02CMS should use appropriate Part C data as part of its reviews of MA contracts' performance.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/10/2024
- Legislative Related
- No
-
Less Than Half of Part D Sponsors Voluntarily Reported Data on Potential Fraud and Abuse
14-E-03-033.03CMS should review data from Part D plan sponsors to determine why certain sponsors reported especially high or low numbers of incidents of potential fraud and abuse, related inquires, and corrective actions.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/07/2024
- Legislative Related
- No
14-E-03-033.04CMS should share Part D plan sponsors' data on potential fraud and abuse with all sponsors and law enforcement.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/07/2022
- Legislative Related
- No
-
Medicare and Beneficiaries Could Realize Substantial Savings If the DRG Window Were Expanded
14-E-05-029.01CMS should seek legislative authority to expand the DRG window to include additional days prior to the inpatient admission.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 05/23/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
14-E-05-029.02CMS should seek legislative authority to expand the DRG window to include other hospital ownership arrangements, such as affiliated hospital groups.- Status
- Closed Superseded
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/08/2022
- Legislative Related
- Yes
-
State Medicaid Program Efforts to Control Costs for Disposable Incontinence Supplies
14-E-07-024.01CMS should encourage State Medicaid programs to seek further cost savings for disposable incontinence supplies.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/19/2021
- Legislative Related
- No
-
Local Coverage Determinations Create Inconsistency in Medicare Coverage
14-E-01-019.01CMS should establish a plan to evaluate new LCDs for national coverage consistent with MMA requirements.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/07/2017
- Next Update Expected
- 07/07/2016
- Legislative Related
- No