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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 positive change, we produce reports and identify recommendations for improvement. We have developed this public-facing page for tracking all of our open recommendations. Learn More
Summary of Recommendations Data
Updated Monthly · Last updated on November 17, 2023
1,344
Open recommendations since start of FY 2000
$268.4B
Potential savings from open recommendations
2,369
Closed recommendations since start of FY 2018
Explore Open Recommendations
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Kentucky Experienced Challenges in Meeting Federal and State Foster Care Program Requirements During the COVID-19 Pandemic
- Audit
- A-06-22-07001
- HHS Agency
- ACF
- Issued
- 11/14/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that Kentucky conduct FBI fingerprint checks on the five applicants and other household members identified by our audit as lacking completed checks. ACF – We recommend that Kentucky conduct the name-based checks on the one applicant and one adolescent household member identified by our audit as lacking the required checks and reiterate to staff the importance of adhering to the policies and procedures requiring background checks to be completed before approving foster homes. ACF – We recommend that Kentucky identify ways to address the challenges related to meeting the requirements for conducting monthly caseworker visits, including consulting with ACF. ACF – -
Pennsylvania Could Better Ensure That Nursing Homes Comply with Federal Requirements for Life Safety, Emergency Preparedness, and Infection Control
- Audit
- A-03-22-00206
- HHS Agency
- CMS
- Issued
- 11/08/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings Work with CMS to refine the current risk-based approach to identify nursing homes at which surveys should be conducted more frequently than once every 15 months, such as those with frequent management turnover. CMS – Work with CMS to develop standardized life safety training for nursing home management teams and staff. CMS – Follow up with the 20 nursing homes reviewed as part of this audit to verify that corrective actions have been taken regarding the life safety, emergency preparedness, and infection control deficiencies identified in this report. CMS – Provide annual written reminders to nursing homes with K-tag, F-tag, and E-tag requirements. CMS – Implement verification standards to confirm completion of written training and training drills. CMS – Work with CMS to improve standardized emergency plan testing and training for nursing home management teams and staff. CMS – Develop a plan in conjunction with CMS to address the foundational issues preventing more frequent surveys at nursing homes with a history of multiple high-risk deficiencies. CMS – Develop additional infection control training resources for nursing home management teams and staff. CMS – -
The Food and Drug Administration Needs To Improve the Premarket Tobacco Application Review Process for Electronic Nicotine Delivery Systems To Protect Public Health
- Audit
- A-06-22-01002
- HHS Agency
- FDA
- Issued
- 11/08/2023
- Report link
- Report pending
Recommendation text Responsible agency Potential savings We recommend that the Center for Tobacco Products assess the PMTA review process and develop an action plan to resolve the backlog of PMTA applications and achieve compliance with the 180-day statutory deadline. FDA – We recommend that the Center for Tobacco Products work with OPM to obtain direct-hire authority to assist CTP in reaching its FTE goal. FDA – -
CMS Can Do More To Leverage Medicare Claims Data To Identify Unreported Incidents of Potential Abuse or Neglect
- Audit
- A-01-22-00501
- HHS Agency
- CMS
- Issued
- 11/08/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Centers for Medicare & Medicaid Services based on the results of the targeted claim reviews, develop and share guidance and best practices with providers to assist providers in reporting incidents in compliance with State mandatory reporting laws. CMS – We recommend that the Centers for Medicare & Medicaid Services conduct data analyses to identify trends and high-risk areas in Medicare claims containing diagnosis codes indicating potential abuse or neglect. CMS – We recommend that the Centers for Medicare & Medicaid Services consider the results of targeted claims reviews when assessing whether the existing requirements for reporting abuse or neglect of Medicare enrollees in provider CoPs should be strengthened. CMS – We recommend that the Centers for Medicare & Medicaid Services provide the results of the analyses to QIOs and Medicare Program Integrity contractors so that they can conduct targeted claim reviews to identify patterns of unreported incidents of potential abuse or neglect and the reasons the incidents were unreported. CMS – -
Noridian Healthcare Solutions Reopened and Corrected Cost Report Final Settlements To Collect $11 Million in Net Overpayments That Had Been Made to Medicare Providers
- Audit
- A-06-22-05000
- HHS Agency
- CMS
- Issued
- 11/01/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that Noridian Healthcare Solutions develop and implement enhanced procedures so that supervisors and higher-level reviewers are better qualified to detect incorrect audit adjustments. CMS – We recommend that Noridian Healthcare Solutions develop and implement procedures to allow enough time for adequate auditor and supervisory review of audit adjustments and related actions. CMS – We recommend that Noridian Healthcare Solutions develop and deliver additional education to auditors and audit supervisors regarding applicable criteria and review requirements. CMS – -
HHS's Oversight of Automatic Provider Relief Fund Payments Was Generally Effective but Improvements Could Be Made
- Audit
- A-02-20-01025
- HHS Agency
- HRSA
- Issued
- 10/30/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Health Resources and Services Administration commit to strengthening its procedures that may apply to future programs of a similar nature to better ensure that; providers receive their intended share of financial assistance; financial assistance payments are properly calculated; data and data sources are appropriate, current, complete, and accurate, and revisions are made when necessary for calculating financial assistance; and all available data sources are utilized to identify ineligible providers and prevent them from receiving financial assistance. HRSA – We recommend that the Health Resources and Services Administration perform postpayment reviews of 58 providers with multiple subsidiary organizations that attested to and kept automatic PRF payments totaling $130 million and recoup any outstanding overpayments from these providers. HRSA $130,044,255 We recommend that the Health Resources and Services Administration perform postpayment reviews of 642 providers that attested to and kept $165 million in automatic PRF payments for which they were not eligible and recoup any outstanding overpayments from these providers. HRSA $164,642,599 We recommend that the Health Resources and Services Administration perform postpayment reviews of 108 renal dialysis providers that attested to and kept automatic PRF payments totaling $58 million and recoup any outstanding overpayments from these providers. HRSA $57,506,122 -
New York City Department of Health and Mental Hygiene Charged Some Unallowable Costs to Its CDC COVID-19 Award
- Audit
- A-04-22-02035
- HHS Agency
- CDC
- Issued
- 10/26/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that NYC DOHMH refund $15,671,958 to the Federal government. CDC $15,671,958 We recommend that NYC DOHMH strengthen its oversight of subrecipients to prevent future unallowable payments by reviewing subrecipient invoices and supporting documentation to ensure costs claimed are allowable and allocable. CDC – -
CDC's Internal Control Weaknesses Led to Its Initial COVID-19 Test Kit Failure, but CDC Ultimately Created a Working Test Kit
- Audit
- A-04-20-02027
- HHS Agency
- CDC
- Issued
- 10/24/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that CDC ensure that all infectious disease laboratories implement and periodically evaluate a QMS. CDC – We recommend that the Centers for Disease Control and Prevention ensure that the recently finalized GRF addresses the findings we identified in this report. CDC – We recommend CDC implement a CDC-wide laboratory document control system. CDC – We recommend that the Centers for Disease Control and Prevention create policies and procedures for developing test kits that include roles, responsibilities, and oversight. CDC – We recommend that CDC re-evaluate the IMS structure at all levels of CDC's response framework and integrate positions or roles and responsibilities that provide effective oversight of a response effort, including a laboratory-based response effort. CDC – We recommend that the Centers for Disease Control and Prevention develop and implement documented processes to ensure that adequate staffing and laboratory space can be obtained for future responses and provide for separation of duties and supervisor controls. CDC – -
States Face Ongoing Challenges in Meeting Third Party Liability Requirements for Ensuring That Medicaid Functions as the Payer of Last Resort
- Audit
- A-05-21-00013
- HHS Agency
- CMS
- Issued
- 10/20/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Centers for Medicare & Medicaid Services ensure that States have current instructions on completing the form 64.9A. CMS – We recommend that the Centers for Medicare & Medicaid Services use the information we obtained from States about the challenges they are still encountering and develop an action plan for helping States more easily identify liable third parties and recover Medicaid payments. CMS – We recommend that the Centers for Medicare & Medicaid Services ensure that States correctly report TPL amounts on the form 64.9A. CMS – We recommend that the Centers for Medicare & Medicaid Services work with States, as appropriate, to encourage better cooperation from third parties that routinely resist States' TPL identification and recovery efforts. CMS – We recommend that the Centers for Medicare & Medicaid Services provide guidance to States to assist them with developing processes that improve the reporting of Medicaid TPL amounts on the form 64.9A. CMS – We recommend that the Centers for Medicare & Medicaid Services remove or disable lines from the form 64.9A that States are supposed to leave blank. CMS – We recommend that the Centers for Medicare & Medicaid Services verify whether Virginia has refunded the $1.25 million Federal share of the Medicaid TPL collections underreported during two fiscal quarters and, if not, require Virginia to refund any remaining amount owed. CMS $1,245,924 We recommend that the Centers for Medicare & Medicaid Services, for the four States we identified as not having fully complied with the DRA's TPL provisions, verify whether the States have since come into compliance; and pursue corrective actions for States that have not fully complied. CMS – -
South Dakota MMIS and E&E System Security Controls Were Partially Effective and Improvements Are Needed
- Audit
- A-18-21-09004
- HHS Agency
- CMS
- Issued
- 10/18/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the South Dakota Department of Social Services remediate the six control findings OIG identified. CMS – -
Mississippi Did Not Always Invoice Rebates to Manufacturers for Physician-Administered Drugs Dispensed to Enrollees of Medicaid Managed-Care Organizations
- Audit
- A-07-21-06103
- HHS Agency
- CMS
- Issued
- 10/18/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Mississippi Division of Medicaid work with CMS to calculate the rebate amount for claims identified in our findings, invoice drug manufacturers for the calculated rebates, and refund the Federal share of rebates collected for the years covered by our audit period and for years after our audit period. CMS $13,707,201 We recommend that the Mississippi Division of Medicaid strengthen internal controls to facilitate the invoicing of all physician-administered drugs for rebate. CMS – -
The Strategic National Stockpile Was Not Positioned To Respond Effectively to the COVID-19 Pandemic
- Audit
- A-04-20-02028
- HHS Agency
- ASPR
- Issued
- 10/16/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that ASPR mitigate the risk presented by relying on foreign supply chains and JIT inventory strategies when determining annual Stockpile purchases. ASPR – We recommend that ASPR reinstate the annual planning and review process and issue to Congress an updated PHEMCE SIP, PHEMCE Multiyear Budget, and Stockpile Annual Review Report. ASPR – We recommend that ASPR develop a strategic plan for the Stockpile, that clearly defines the goals and objectives of the Stockpile, and the Stockpile's roles and responsibilities for responding to emergency events, including pandemics. ASPR – We recommend that ASPR work to increase the Stockpile's annual funding to keep pace with the Stockpile's increased responsibilities. ASPR – We recommend that ASPR develop a plan and timeline for fully integrating the Stockpile within ASPR. ASPR – We recommend that ASPR develop a response plan, to include communication plans, for situations in which the Stockpile needs to respond to changes in roles and responsibilities during large-scale emergency responses. ASPR – -
Medicare Could Save Millions if It Implements an Expanded Hospital Transfer Payment Policy for Early Discharges to Post Acute Care
- Audit
- A-01-21-00504
- HHS Agency
- CMS
- Issued
- 10/06/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that CMS conduct an analysis of its hospital transfer payment policy for discharges to PAC and expand the policy as necessary. CMS $694,000,000 -
Medicare Advantage Compliance Audit of Specific Diagnosis Codes That Aetna, Inc. (Contract H5521) Submitted to CMS
- Audit
- A-01-18-00504
- HHS Agency
- CMS
- Issued
- 10/02/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that Aetna, Inc. determine, for the remaining 159 enrollee-years in the potentially mis-keyed diagnosis code high-risk group not reviewed as part of this audit, whether the medical records in each case support the diagnosis for the unrelated condition and refund any resulting overpayments to the Federal Government. CMS – We recommend that Aetna, Inc. refund to the Federal Government the $632,070 of overpayments. CMS $632,070 We recommend that Aetna, Inc. identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government. CMS – We recommend that Aetna, Inc. continue to examine its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures. CMS – -
New Jersey Could Better Ensure That Nursing Homes Comply With Federal Requirements for Life Safety, Emergency Preparedness, and Infection Control
- Audit
- A-02-22-01004
- HHS Agency
- CMS
- Issued
- 09/29/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the New Jersey Department of Health work with CMS to develop a risk-based approach to identify nursing homes where surveys should be conducted more frequently than once every 15 months, such as those with a history of multiple high-risk deficiencies or frequent management turnover. CMS – We recommend that the New Jersey Department of Health instruct all nursing homes to install carbon monoxide detectors in accordance with New Jersey requirements. CMS – We recommend that the New Jersey Department of Health follow up with the 20 nursing homes reviewed in this audit that demonstrated life safety, emergency preparedness, and infection control deficiencies to ensure that they have taken corrective actions. CMS – We recommend that the New Jersey Department of Health work with CMS to develop standardized life safety training for nursing home staff. CMS – We recommend that the New Jersey Department of Health work with CMS to develop a plan to address the foundational issues preventing more frequent surveys at nursing homes with a history of multiple high-risk deficiencies. CMS – -
District of Columbia Medicaid Fraud Control Unit: 2022 Review
- Evaluation
- OEI-06-22-00420
- HHS Agency
- MFCU
- Issued
- 09/26/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings Ensure that supervisory reviews of case files are conducted and documented in accordance with Unit policy. OIG-MFCU – Develop policies and procedures to implement the District of Columbia OIG's expanded law enforcement authority and ensure that Unit investigators receive training on the new authorities. OIG-MFCU – Ensure that all convictions and adverse actions are reported to Federal partners within the appropriate timeframes. OIG-MFCU – Build upon its efforts with the District's Medicaid agency to increase fraud referrals from the MCOs. OIG-MFCU – -
Biosimilars Have Lowered Costs for Medicare Part B and Enrollees, but Opportunities for Substantial Spending Reductions Still Exist
- Evaluation
- OEI-05-22-00140
- HHS Agency
- CMS
- Issued
- 09/26/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings CMS should pursue one or more payment changes that could further realize savings from biosimilars for Part B and enrollees. CMS – -
Home Health Agencies Rarely Furnished Services Via Telehealth Early in the COVID-19 Public Health Emergency
- Audit
- A-05-21-00026
- HHS Agency
- CMS
- Issued
- 09/25/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that CMS monitor HHA reporting of the new G-codes to determine whether further updates to regulations or guidance are necessary. CMS – -
Many Medicaid Enrollees with Opioid Use Disorder Were Treated with Medication; However, Disparities Present Concerns
- Evaluation
- OEI-BL-22-00260
- HHS Agency
- CMS
- Issued
- 09/25/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings CMS should encourage and support States' efforts to reduce barriers to MOUD, especially among groups who may be underserved. CMS – CMS should encourage States and work with Federal partners to educate Medicaid and CHIP enrollees about access to MOUD. CMS – -
Medicare Advantage Compliance Audit of Diagnosis Codes That Health Net of California, Inc. (Contract H0562) Submitted to CMS
- Audit
- A-09-18-03007
- HHS Agency
- CMS
- Issued
- 09/22/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that Health Net of California, Inc. continue to improve its policies and procedures to prevent, detect, and correct noncompliance with Federal requirements for diagnosis codes that are used to calculate risk-adjusted payments. CMS – We recommend that Health Net of California, Inc. refund to the Federal Government the $69,182 of net overpayments. CMS $69,182