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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 March 15, 2023
1,392
Open recommendations since start of FY 2000
$257.0B
Potential savings from open recommendations
1,638
Closed recommendations since start of FY 2018
Explore Open Recommendations
Showing 1–20 of 525 reports, containing 1,392 recommendations
Sorted by most recent report
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Medicare Improperly Paid Physicians for Epidural Steroid Injection Sessions
- Audit
- A-07-21-00618
- HHS Agency
- CMS
- Issued
- 03/10/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Centers for Medicare and Medicaid Services assess the effectiveness of oversight mechanisms, put in place after our audit period, that are specific to preventing or detecting improper payments to physicians for more than 4 epidural steroid injection sessions in a 12-month period and modify the oversight mechanisms, if necessary, based on that assessment. CMS – We recommended that Centers for Medicare and Medicaid Services direct the MACs (or other CMS-designated entities) to review a sample of claims for epidural steroid injection sessions administered during the period beginning on January 1, 2021, and ending on the date that the revised coverage limitations (i.e., up to four sessions per 12-month period) became effective in the relevant MAC's jurisdiction (I.e. December 5, 2021, and June 19, 2022), to identify instances in which Medicare paid physicians for injection sessions that exceeded the number of allowable sessions (in accordance with the applicable LCDs) and recover any improper payments identified. CMS – We recommend that the Centers for Medicare and Medicaid Services instruct the MACs to, based on the results of this audit, notify appropriate physicians (i.e. those for whom CMS determines this audit constitutes credible information of potential overpauments) so that the physicians can exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation. CMS – We recommend that the Centers for Medicare and Medicaid Services direct the MACs to recover the $3,585,422 in improper payments made to physicians for epidural steroid injection sessions. CMS $3,585,422 -
Florida Did Not Invoice Manufacturers for Some Rebates for Physician-Administered Drugs Dispensed to Enrollees of Medicaid Managed-Care Organizations
- Audit
- A-04-21-07098
- HHS Agency
- CMS
- Issued
- 03/03/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Florida Agency for Health Care Administration work with CMS to determine whether the other claims for multiple-source physician-administered drugs, totaling $40,635 ($24,772 Federal share), were eligible for rebates and, if so, determine the rebates due and, upon receipt of the rebates, refund the Federal share of the rebates collected. CMS $24,772 We recommend that the Florida Agency for Health Care Administration ensure that all physician-administered drugs eligible for rebates after our audit period are processed for rebates. CMS – We recommend that the Florida Agency for Health Care Administration invoice for, and collect from manufacturers, an estimated $57,700 ($35,126 Federal share) in rebates for single-source physician-administered drugs and refund the Federal share of rebates collected. CMS $35,126 -
State Agencies Did Not Always Ensure That Children Missing From Foster Care Were Reported to the National Center for Missing and Exploited Children in Accordance With Federal Requirements
- Audit
- A-07-21-06102
- HHS Agency
- ACF
- Issued
- 03/02/2023
- Report link
- Report pending
Recommendation text Responsible agency Potential savings We recommend that the Administration for Children and Families work with State agencies to ensure compliance with Federal requirements to report missing children episodes to NCMEC in a timely manner. ACF – -
Medicare Part D Plan Sponsors and CMS Did Not Ensure That Transmucosal Immediate-Release Fentanyl Drugs Were Dispensed Only to Beneficiaries Who Had a Cancer Diagnosis
- Audit
- A-09-20-03033
- HHS Agency
- CMS
- Issued
- 02/28/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to conduct data analysis and follow up on information that is inconsistent between the Medicare claims data and prior authorization information obtained for TIRF drug prescriptions. CMS – We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to delete the PDEs related to the $86,247,325 of unallowable Medicare Part D total costs and determine after reconciliation the impact to the Federal Government. CMS $86,247,325 We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to identify and delete any unallowable PDEs related to the $19,704,602 of Medicare Part D total costs for beneficiaries whose most recent Medicare claim with a cancer diagnosis was for services provided more than 1 year before the TIRF drugs were dispensed, and determine the impact to the Federal Government. CMS $19,704,602 We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to expand the required PDE data elements to include diagnosis codes to enable plan sponsors to confirm that TIRF drugs are prescribed for a medically accepted indication. CMS – We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to ensure that plan sponsors obtain sufficient information during the prior authorization process so that TIRF drugs are dispensed only to beneficiaries with a medically accepted indication of breakthrough cancer pain. CMS – -
Medicare Could Have Saved up to $216 Million Over 5 Years if Program Safeguards Had Prevented At-Risk Payments for Definitive Drug Testing Services
- Audit
- A-09-21-03006
- HHS Agency
- CMS
- Issued
- 02/27/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Centers for Medicare & Medicaid Services expand program safeguards to prevent and detect at-risk payments to at-risk providers for the definitive drug testing service with the highest reimbursement amount (procedure code G0483), which could have saved up to $215.8 million for our audit period. CMS $215,839,412 We recommend that the Centers for Medicare & Medicaid Services educate providers that received payments that did not comply with Medicare requirements for definitive drug testing services. CMS – We recommend that the Centers for Medicare & Medicaid Services review at-risk payments made to at-risk providers during and after our audit period to determine whether payments for procedure code G0483 complied with Medicare requirements and recover any overpayments. CMS – We recommend that the Centers for Medicare & Medicaid Services notify appropriate providers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the providers can exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation. CMS – -
The Inability To Identify Denied Claims in Medicare Advantage Hinders Fraud Oversight
- Evaluation
- OEI-03-21-00380
- HHS Agency
- CMS
- Issued
- 02/27/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings CMS should require MAOs to definitively indicate on MA encounter data records when they have denied payment for a service on a claim. CMS – -
Missouri Claimed Federal Medicaid Reimbursement for Tens of Millions in Consumer-Directed Personal Care Assistance Services That Did Not Comply With Federal and State Requirements
- Audit
- A-07-20-03243
- HHS Agency
- CMS
- Issued
- 02/23/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Missouri Department of Social Services monitor consumer-directed PCA providers to ensure compliance with the State agency's established policies and procedures such that timesheets are completed and the tasks performed are described accurately and in sufficient detail; units of service charged on timesheets do not exceed the units allowable on the recipients' plans of care; consumer-directed PCA providers maintain documentation showing that attendants are registered, screened, and employable pursuant to the FCSR; and plans of care are signed. CMS – We recommend that the Missouri Department of Social Services refund $34,171,397 (Federal share) in overpayments to the Federal Government. CMS $34,171,397 We recommend that the Missouri Department of Social Services work with CMS to determine the allowability of $87,018,594 (Federal share) that we have set aside, and refund to the Federal Government any amount that is determined to be unallowable. CMS $87,018,594 We recommend that the Missouri Department of Social Services establish policies and procedures to ensure that timesheets include fully accurate and complete details on the specific tasks performed. CMS – We recommend that the Missouri Department of Social Services establish and implement policies and procedures to specify what consumer-directed PCA providers must include in their emergency backup plans for recipients and require development of pandemic preparedness plans and implement training to educate consumer-directed PCA providers on these plans. CMS – -
The Health Resources and Services Administration Should Improve Preventive and Detective Controls To More Effectively Mitigate the Risk of Compromise
- Audit
- A-18-20-08200
- HHS Agency
- HRSA
- Issued
- 02/22/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Health Resources and Services Administration implement policies and procedures to periodically identify and assess whether security controls are in place and operating effectively in accordance with the most current NIST SP 800-53 and remediate weak controls timely. HRSA – We recommend that the Health Resources and Services Administration remediate the nine security control findings we identified. HRSA – We recommend that the Health Resources and Services Administration update security configurations to align with the most current NIST SP 800-53 security controls. HRSA – -
Florida Made Capitation Payments for Enrollees Who Were Concurrently Enrolled in a Medicaid Managed Care Program in Another State
- Audit
- A-05-21-00028
- HHS Agency
- CMS
- Issued
- 02/16/2023
- Report link
- Report pending
Recommendation text Responsible agency Potential savings We recommend that the Florida Agency for Health Care Administration work with CMS to consider the potential use of T-MSIS data to identify potential cases of concurrent enrollment. CMS – We recommend that the Florida Agency for Health Care Administration resume and enhance procedures that are in accordance with Federal requirements and the State's unwinding plan to identify and disenroll enrollees who are residing and enrolled in Medicaid managed care in another State when the PHE ends. CMS – -
Michigan Did Not Comply With Requirements for Documenting Psychotropic and Opioid Medications Prescribed for Children in Foster Care
- Audit
- A-05-21-00030
- HHS Agency
- ACF
- Issued
- 02/08/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Michigan Department of Health and Human Services ensure that electronic case records for the children under its care and supervision are maintained in accordance with State requirements by modifying procedures for the monitoring of caseworkers to include a review of medical passports in MiSACWIS. ACF – We recommend that the Michigan Department of Health and Human Services ensure the electronic case records for children who are prescribed opioid medications are maintained in accordance with requirements by implementing procedures requiring caseworkers to monitor Medicaid claim data for opioid medications prescribed for the children and providing training to caseworkers on the requirements for documenting medications prescribed for the children in MiSACWIS, including opioid medications due to medical procedures or emergency treatments. ACF – We recommend that the Michigan Department of Health and Human Services ensure the electronic case records for children who are prescribed psychotropic medications are maintained in accordance with requirements by implementing policies specific to non-emergency situations that require the FC-PMOU to document when consent forms do not need to be obtained; implementing procedures for caseworkers and the FC-PMOU to monitor the Medicaid claim data to ensure consent forms are obtained and documented; and implementing procedures requiring caseworkers and the FC-PMOU to monitor other medications prescribed for children, including opioids, for potential medication interaction and adverse side effects. ACF – -
North Carolina Did Not Always Invoice Rebates to Manufacturers for Physician-Administered Drugs
- Audit
- A-07-21-07002
- HHS Agency
- CMS
- Issued
- 02/07/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the North Carolina Department of Health and Human Services, Division of Health Benefits refund to the Federal Government $2,324,567 (Federal share) for claims for single source physician-administered drugs that were ineligible for Federal reimbursement. CMS $2,324,567 We recommend that the North Carolina Department of Health and Human Services, Division of Health Benefits work with CMS to determine the unallowable portion of $684,731 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement, refund that amount, and consider invoicing drug manufacturers for rebates for these drugs if CMS determines that the drug claims are allowable. CMS $684,731 We recommend that the North Carolina Department of Health and Human Services, Division of Health Benefits refund to the Federal Government $733,535 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement. CMS $733,535 We recommend that the North Carolina Department of Health and Human Services, Division of Health Benefits work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not invoiced for rebates after December 31, 2019. CMS – We recommend that the North Carolina Department of Health and Human Services, Division of Health Benefits to strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced. CMS – -
Early Challenges Highlight Areas for Improvement in COVID-19 Vaccination Programs
- Evaluation
- OEI-04-21-00190
- HHS Agency
- CDC
- Issued
- 01/27/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings CDC should update its plans for mass vaccination programs with strategies that address awardee-reported logistical challenges. CDC – CDC should strengthen reporting of vaccine allocation data and administration data. CDC – CDC should clarify roles and responsibilities within HHS for vaccine public health messaging during a pandemic. CDC – CDC should work with awardees to enhance current and future capabilities for provider training and oversight. CDC – -
Challenges With Data From Federal Vaccination Partners Hinder Efforts by State and Local Immunization Programs To Combat COVID-19
- Evaluation
- OEI-05-22-00010
- HHS Agency
- CDC
- Issued
- 01/27/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings CDC should provide educational outreach to ensure that State and local immunization programs are aware of existing tools to address vaccination campaign needs. CDC – CDC should work with State and local immunization programs and retail pharmacy partners to mitigate reported data gaps and timeliness challenges. CDC – -
Greater Bergen Community Action, Inc., Did Not Manage Its Head Start Awards in Accordance With Federal and State Requirements
- Audit
- A-02-19-02008
- HHS Agency
- ACF
- Issued
- 01/26/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings Strengthen its policies and procedures to ensure that grant drawdowns are used to cover immediate cash needs necessary for its Head Start expenditures; only allowable costs are charged to the Head Start program; vehicle usage costs are adequately supported; and background checks and health screenings are performed on all volunteers who provide more than 20 percent of services during GBCA's weekly operating hours. ACF – Refund $394,733 to the Federal Government for unallowable costs charged to the Head Start awards. ACF $394,733 Work with ACF to determine the amount of allowable vehicle costs or refund $92,678 to the Federal Government for potentially unallowable vehicle costs. ACF $92,678 -
The National Institutes of Health and EcoHealth Alliance Did Not Effectively Monitor Awards and Subawards, Resulting in Missed Opportunities to Oversee Research and Other Deficiencies
- Audit
- A-05-21-00025
- HHS Agency
- NIH
- Issued
- 01/25/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the National Institutes of Health work with EcoHealth to recover identified unallowable costs, along with salary costs in excess of the NIH salary cap and bonus costs that were not sampled. NIH – We recommend that the National Institutes of Health ensure that EcoHealth accurately and in a timely manner reports award and subaward information, including in: recipient progress reports; the Federal Funding Accountability and Transparency Act of 2006, Subawarding Reporting System; and recipient-audited financial statements. NIH – We recommend that the National Institutes of Health ensure that administrative actions such as terminations are performed in compliance with Federal regulations and HHS policies and procedures, and appropriate notifications of appeal rights are provided. NIH – We recommend that the National Institutes of Health work with EcoHealth to determine whether EcoHealth had any unreimbursed costs at the time award R01AI110964 was terminated. NIH – We recommend that the National Institutes of Health assess whether NIAID staff are following the NIAID P3CO policy, including erring on the side of inclusion when determining whether proposed research should be referred to the NIAID DURC/P3CO Committee for research proposals that may involve ePPP. NIH – We recommend that the National Institutes of Health based on information provided in this audit and any other information available to NIH, consider whether it is appropriate to refer WIV to HHS for debarment and exercise continued monitoring and enforcement activities as appropriate over the course of the grant awards and subawards. NIH – We recommend that the National Institutes of Health ensure for any future NIH grant awards that EcoHealth has addressed the deficiencies noted in the report. NIH – We recommend that EcoHealth Alliance prepare subaward and consultant agreements that contain all required information and are accurate. NIH – We recommend that EcoHealth Alliance submit progress reports by the required due date. NIH – We recommend that the National Institutes of Health implement enhanced monitoring, documentation, and reporting requirements for recipients with foreign subrecipients. NIH – We recommend that EcoHealth Alliance comply with requirements to immediately notify NIH of conditions that materially impact the ability to meet award objectives. NIH – We recommend that EcoHealth Alliance ensure that it has the ability to access all records related to its research conducted at subrecipient locations. NIH – We recommend that EcoHealth Alliance properly identify subawards in financial statements. NIH – We recommend that EcoHealth Alliance report subawards according to FFATA requirements. NIH – We recommend that the National Institutes of Health define the process and timeline for what NIH considers "immediate notification" as it relates to specific award conditions intended to report unexpected research outcomes. NIH – We recommend EcoHealth Alliance refund to the Government $89,171 in unallowable costs consisting of: 1. salary costs claimed in excess of the NIH salary cap totaling $10,627; 2. bonus costs totaling $15,977; 3. indirect and fringe benefits associated with salary and bonus costs totaling $17,836; 4. Ph.D. education tuition costs totaling $13,951 and associated indirect costs of $4,641; 5. Indirect costs totaling $13,037 claimed by a subrecipient; 6. travel costs totaling $5,752 and associated indirect costs of $1,876; 7. visa costs of $2,500 and associated indirect costs of $896; 8. subaward costs of $2,052; and 9. professional fees costs of $19 and associated indirect costs of $7. NIH $89,171 -
ASPR Could Improve Its Oversight of the Hospital Preparedness Program To Ensure That Crisis Standards of Care Comply With Federal Nondiscrimination Laws
- Audit
- A-01-21-01502
- HHS Agency
- ASPR
- Issued
- 01/13/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Administration for Strategic Preparedness and Response consider additional updates to the current HPP cooperative agreement to promote that HPP recipients adopt CSCs that comply with Federal nondiscrimination laws. We acknowledge that ASPR has taken steps in previous HPP updates to promote compliance with Federal nondiscrimination laws; however, we believe additional steps can be taken. Such steps could include an additional update to the HPP cooperative agreement to encourage recipients to engage with advocacy groups in decision making related to crisis care planning. ASPR – -
FDA Should Improve Its Management of Contracts for the Acquisition of Information Technology
- Audit
- A-18-21-11100
- HHS Agency
- FDA
- Issued
- 01/13/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that the Food and Drug Administration consistently implement its existing policies and procedures and use existing checklists to ensure that the appropriate contracting documents and supporting documents are uploaded to the Purchase Request Information System (PRISM), and the Severability & Funding Determination and Recommendation for Award approvals are properly completed. FDA – We recommend that the Food and Drug Administration consistently implement its existing policies and procedures and use existing checklists to ensure that contractor performance assessments are completed and uploaded to the Contractor Performance Assessment Reporting System timely. FDA – We recommend that the Food and Drug Administration prepare and submit timely Annual Competition Advocate Reports (ACARS) to HHS in accordance with the requirements of FAR 6.502(b)(2) and the HHS Competition Advocacy Directive. FDA – We recommend that the Food and Drug Administration evaluate internal procedures and documents for key contracting decisions and activities to verify that all supporting contract documents are based on current HHS and FDA policies and procedures. FDA – We recommend that the Food and Drug Administration consistently implement its existing policies and procedures and use existing checklists to ensure that contracting officer's representatives (CORs) are appointed using the required COR Memo if the contracting officer does not retain and complete all COR duties. FDA – -
More Than a Thousand Nursing Homes Reached Infection Rates of 75 Percent or More in the First Year of the COVID-19 Pandemic; Better Protections Are Needed for Future Emergencies
- Evaluation
- OEI-02-20-00491
- HHS Agency
- CMS
- Issued
- 01/12/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings CMS should improve how surveys identify infection control risks to nursing home residents and strengthen guidance on assessing the scope and severity of those risks. CMS – CMS should target nursing homes in most need of infection control intervention, and provide enhanced oversight and technical assistance to these facilities as appropriate. CMS – CMS should re-examine current nursing staff requirements and revise them as necessary. CMS – -
National Government Services, Inc., Claimed Some Unallowable Medicare Pension Costs Through Its Incurred Cost Proposals
- Audit
- A-07-22-00623
- HHS Agency
- CMS
- Issued
- 01/07/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that National Government Services, Inc., work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare pension costs of $73,307 for CYs 2015 through 2018. CMS $73,307 -
National Government Services, Inc., Overstated Its United Government Services, LLC, Medicare Segment Pension Assets and Understated Medicare's Share of the Medicare Segment Excess Pension Liabilities as of December 31, 2018
- Audit
- A-07-22-00622
- HHS Agency
- CMS
- Issued
- 01/06/2023
- Report link
- View report
Recommendation text Responsible agency Potential savings We recommend that National Government Services, Inc., develop quality assurance procedures, to include improved policies and procedures, to ensure that going forward, it calculates Medicare segment pension assets in accordance with Federal requirements. CMS – We recommend that National Government Services, Inc. increase Medicare's share of the UGS Medicare segment excess pension liabilities as of December 31, 2018, by $69,360 and recognize $510,580 as Medicare's share of the pension liabilities as a result of the benefit curtailment. CMS – We recommend that National Government Services, Inc. decrease the UGS Medicare segment pension assets by $66,663 and recognize $2,618,341 as the UGS Medicare segment pension assets as of December 31, 2018. CMS –