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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 1,141–1,160 of 1,223 reports, containing 4,008 recommendations
Sorted by latest release date
-
The ESRD Beneficiary Grievance Process
14-E-01-016.04CMS should work with AHRQ to add a question to CAHPS to assess beneficiaries' fear of reprisal.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/17/2023
- Next Update Expected
- 11/07/2024
- Legislative Related
- No
-
Not All Recommended Fraud Safeguards Have Been Implemented in Hospital EHR Technology
14-E-01-015.01CMS and ONC should make audit logs be operational whenever EHR technology is available for updates or viewing.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/25/2016
- Next Update Expected
- 06/08/2014
- Legislative Related
- No
14-E-01-015.02ONC and CMS should make audit logs be operational whenever EHR technology is available for updates or viewing.- Status
- Open Unimplemented
- Responsible Agency
- ONC
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/01/2016
- Next Update Expected
- 06/08/2014
- Legislative Related
- No
14-E-01-015.03ONC and CMS should strengthen their collaborative efforts to develop a comprehensive plan to address fraud vulnerabilities in EHRs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 05/21/2019
- Next Update Expected
- 06/08/2014
- Legislative Related
- No
14-E-01-015.04ONC and CMS should strengthen their collaborative efforts to develop a comprehensive plan to address fraud vulnerabilities in EHRs.- Status
- Open Unimplemented
- Responsible Agency
- ONC
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 05/21/2019
- Next Update Expected
- 06/08/2014
- Legislative Related
- No
-
Medicare Hospital Outlier Payments Warrant Increased Scrutiny
14-E-06-012.01CMS should instruct Medicare contractors to increase monitoring of outlier payments.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/30/2024
- Legislative Related
- No
-
The First Level of the Medicare Appeals Process, 2008-2012: Volume, Outcomes, and Timeliness
14-E-01-001.01CMS should use the Medicare Appeals System (MAS) to monitor contractor performance.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 08/12/2024
- Next Update Expected
- 08/22/2025
- Legislative Related
- No
-
New York State Improperly Claimed Medicaid Reimbursement for Some Home Health Services Claims Submitted by Certified Home Health Agencies
13-A-02-331.01We recommend that the State agency refund $31,482,913 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $31,482,913
- Last Update Received
- 07/11/2023
- Next Update Expected
- 01/11/2024
- Legislative Related
- No
-
Medicare Could Collect Billions If Pharmaceutical Manufacturers Were Required To Pay Rebates for Part B Drugs
13-E-12-070.01CMS should examine the additional potential impacts of establishing a prescription drug rebate program under Medicare Part B and, if appropriate, seek legislative change.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/13/2023
- Legislative Related
- Yes
-
New York Claimed Hospital-Based Continuing Day Treatment Services That Were Not in Compliance With Federal and State Requirements
13-A-02-313.01That NYS DOH refund $8,281,766 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $8,281,766
- Last Update Received
- 03/24/2024
- Next Update Expected
- 09/24/2024
- Legislative Related
- No
-
Most Critical Access Hospitals Would Not Meet the Location Requirements If Required To Re-enroll in Medicare
13-E-05-063.01CMS should seek legislative authority to remove Necessary Provider CAHs' permanent exemption from the distance requirement, thus allowing CMS to Reassess these CAHs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/30/2023
- Next Update Expected
- 07/01/2023
- Legislative Related
- Yes
13-E-05-063.02CMS should seek legislative authority to revise the CAH Conditions of Participation to include alternative location-related requirements.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/08/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
-
Medicare's Currently Not Collectible Overpayments
13-E-03-057.01CMS should ensure that the HIGLAS variable for provider type is populated for all overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/21/2023
- Legislative Related
- No
13-E-03-057.02CMS should ensure that demand letters are mailed to the contacts and addresses identified by the provider.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/16/2023
- Legislative Related
- No
-
Replacement Schedules for Medicare Continuous Positive Airway Pressure Supplies
13-E-07-053.01CMS should review the CPAP supply replacement schedule and revise the national coverage determination for CPAP therapy for OSA or request that the DME MACs revise their LCDs as appropriate.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/04/2024
- Legislative Related
- No
-
Indiana Improperly Claimed Federal Reimbursement for All Reviewed Medicaid Inpatient Psychiatric Hospital Service Payments to Evansville State Hospital
13-A-05-262.01We recommend that the State Medicaid agency refund $7,092,206 to the Federal Government for its share of inpatient psychiatric service payments made to Evansville for claims with dates of service when it did not demonstrate compliance with the special Medicare CoP.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $7,092,206
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
13-A-05-262.02We recommend that the State Medicaid agency ensure that Federal reimbursement for Medicaid inpatient psychiatric service payments to psychiatric hospitals is claimed only if those hospitals 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
-
Missouri Improperly Claimed Federal Reimbursement for Most Reviewed Medicaid Inpatient Psychiatric Hospital Service and Disproportionate Share Hospital Payments to Hawthorn Children's Psychiatric Hospital
13-A-05-263.01We recommend that the State agency refund $21,375,765 to the Federal Government for its share of Medicaid inpatient psychiatric service and DSH payments made to Hawthorn for claims with dates of service outside the regulatory gap period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $21,375,765
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
13-A-05-263.02We recommend that the State agency work with CMS to determine whether the State agency should refund an additional $1,346,500 to the Federal Government for its share of payments made to Hawthorn for claims with dates of service during the regulatory gap period.- 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
13-A-05-263.03We recommend that the State agency identify and refund the Federal share of any additional payments made to Hawthorn for claims with dates of service after the audit period if neither the State agency nor Hawthorn can demonstrate the hospital's compliance with Federal requirements for inpatient psychiatric hospital 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
-
The University of Colorado Denver Did Not Always Claim Selected Costs Charged Directly to Department of Health and Human Services Awards in Accordance With Federal Regulations
13-A-07-243.01We recommend that the University refund $1,419,524 to the Federal Government.- Status
- Closed Unimplemented
- Responsible Agency
- NIH
- Response
- Partial Concur
- Potential Savings
- $1,419,524
- Last Update Received
- -
- Closed Date
- 05/04/2023
- Legislative Related
- No
13-A-07-243.02We recommend that the University exercise more stringent oversight of charges to Federal awards to ensure compliance with Federal regulations.- Status
- Closed Unimplemented
- Responsible Agency
- NIH
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/04/2023
- Legislative Related
- No
-
Indiana Improperly Claimed Federal Reimbursement for Most Medicaid Inpatient Psychiatric Hospital Service and Disproportionate Share Hospital Payments to Evansville Psychiatric Children's Center
13-A-05-232.01We recommend that the State Medicaid agency refund $7,567,455 to the Federal Government for its share of inpatient psychiatric service and DSH payments made to Evansville for claims with dates of service outside the regulatory gap period when it did not demonstrate compliance with the basic and special Medicare CoP.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $7,567,455
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
13-A-05-232.02We recommend that the State Medicaid agency work with CMS to determine whether the State Medicaid agency should refund an additional $345,889 to the Federal Government for its share of payments made to Evansville for claims with dates of service during the regulatory gap period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $345,889
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
13-A-05-232.03We recommend that the State Medicaid agency ensure that Federal reimbursement for Medicaid inpatient psychiatric service and DSH payments to psychiatric hospitals is claimed only if those hospitals can demonstrate compliance with the basic and 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's Claims for Medicaid Services Provided Under Its Traumatic Brain Injury Waiver Program Did Not Comply With Certain Federal and State Requirements
13-A-02-225.01We recommended that the New York Department of Health (Health Department) refund $54,265,195 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $54,265,195
- Last Update Received
- 08/26/2024
- Next Update Expected
- 03/12/2025
- Legislative Related
- No
13-A-02-225.02We recommended that the Health Department work with CMS to resolve the claims, totaling $662,510, for which Medicaid reimbursement may have been unallowable.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
13-A-02-225.03We recommended that the Health Department ensure that it complies with certain Federal and State requirements by requiring (1) the centers to ensure and document that all beneficiaries approved for TBI waiver program services have been assessed by certified individuals and are eligible for those services, (2) adequate training for assessors on the Federal and State requirements for the TBI waiver program, and (3) providers to ensure that they document TBI waiver program services billed and claim reimbursement only for allowable ones.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
-
New York Improperly Claimed Medicaid Reimbursement for Family-Based Treatment Rehabilitation Services
13-A-02-170.01We recommend that the State agency refund $27,467,320 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $27,467,320
- Last Update Received
- 09/24/2024
- Next Update Expected
- 03/27/2025
- Legislative Related
- No
-
Gaps in Oversight of Conflicts of Interest in Medicare Prescription Drug Decisions
13-E-05-034.01CMS should define Pharmacy Benefit Managers (PBM) as entities that could benefit from formulary decisions.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 05/23/2024
- Next Update Expected
- 07/02/2025
- Legislative Related
- No
13-E-05-034.02CMS should establish minimum standards requiring sponsors to ensure that safeguards are established to prevent improprieties related to employment by the entity that maintains the Pharmacy and Therapeutics (P&T) committee.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 05/23/2024
- Next Update Expected
- 07/02/2025
- Legislative Related
- No
13-E-05-034.05CMS should oversee compliance with Federal P&T committee conflict-of-interest requirements and guidance.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/20/2016
- Next Update Expected
- 09/03/2013
- Legislative Related
- No
-
FDA Lacks Comprehensive Data To Determine Whether Risk Evaluation and Mitigation Strategies Improve Drug Safety
13-E-04-029.06FDA should seek legislative authority to enforce FDA assessment plans.- Status
- Open Unimplemented
- Responsible Agency
- FDA
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/19/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
13-E-04-029.07FDA should ensure that assessment reviews are timely.- Status
- Open Unimplemented
- Responsible Agency
- FDA
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/19/2024
- Next Update Expected
- 04/22/2025
- Legislative Related
- No
-
Indiana Improperly Claimed Federal Reimbursement for All Reviewed Medicaid Inpatient Psychiatric Hospital Service Payments to Logansport State Hospital
13-A-05-129.01We recommend that the State agency refund $5,841,815 to the Federal Government for its share of inpatient psychiatric service payments made to Logansport for claims with dates of service when it did not demonstrate compliance with the special Medicare CoP.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $5,841,815
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
13-A-05-129.02We recommend that the State agency identify and refund the Federal share of any additional payments made to Logansport for claims with dates of service after the audit period if neither the State agency nor Logansport can demonstrate the hospital's compliance with Federal requirements for inpatient psychiatric hospital 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
13-A-05-129.03We recommend that the State agency ensure that Federal reimbursement for Medicaid inpatient psychiatric service payments to psychiatric hospitals is claimed only if those hospitals 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
-
Comparison of Average Sales Prices and Average Manufacturer Prices: An Overview of 2011
13-E-03-028.04CMS should consider seeking a legislative change to require manufacturers of Part B-covered drugs to submit both ASPs and AMPs.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/20/2023
- Legislative Related
- Yes