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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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Showing 21–40 of 516 reports, containing 1,344 recommendations Sorted by most recent report

Audit: A-06-21-09002
HHS Agency: CMS
Issued: 09/22/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Centers for Medicare & Medicaid Services work with Minnesota to determine whether Medicaid enrollees were responsible for any cost-sharing for COVID-19 testing, services, or treatments and, if any cost-sharing is identified, work with Minnesota to ensure that enrollees are reimbursed for any out-of-pocket expenses incurred.	CMS	–
We recommend that the Centers for Medicare & Medicaid Services work with the four States to determine what amount, if any, of the funding they received because of the increased COVID-19 FMAP should be refunded to the Federal Government.	CMS	–

Audit: A-04-21-08090
HHS Agency: CMS
Issued: 09/21/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Alabama Medicaid Agency refund to the Federal Government $43,981 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.	CMS	$43,981
We recommend that the Alabama Medicaid Agency 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 Alabama Medicaid Agency refund to the Federal Government $14,960,673 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.	CMS	$14,960,673
We recommend that the Alabama Medicaid Agency strengthen its internal controls to ensure that all pharmacy and physician-administered drugs eligible for rebates are invoiced.	CMS	–
We recommend that the Alabama Medicaid Agency work with CMS to determine and refund the unallowable portion of $290,455 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement and consider invoicing drug manufacturers for rebates for those drug claims that CMS determines are allowable.	CMS	$290,455
We recommend that the Alabama Medicaid Agency complete the process for rebating pharmacy drugs totaling $6,568 ($4,719 Federal share) for single-source and $219,220 ($157,395 Federal share) for multiple-source drugs that it had not previously collected a rebate on or refund the Federal share.	CMS	$162,114

Evaluation: OEI-01-20-00240
HHS Agency: FDA
Issued: 09/18/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
FDA should give greater weight to retailers' past noncompliance when taking enforcement actions against retailers with histories of violations.	FDA	–
FDA should determine whether variation in inspection activity on the basis of neighborhoods' socioeconomic status is appropriate and the extent to which it is meeting FDA's objective for protecting vulnerable populations.	FDA	–

Audit: A-02-21-01016
HHS Agency: CMS
Issued: 09/18/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that New York use the findings in this report to determine whether Centers Plan for Healthy Living (CPHL) was noncompliant and determine whether a corrective action plan or other sanctions are appropriate.	CMS	–
We recommend that New York review Centers Plan for Healthy Living's (CPHL's) appeal process and ensure that CPHL makes any necessary changes to comply with requirements for denying services.	CMS	–
We recommend that New York implement procedures to obtain and review information related to MCOs' initial denials and internal appeals.	CMS	–

Audit: A-07-22-07007
HHS Agency: CMS
Issued: 09/13/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that Amerigroup Iowa, Inc., coordinate with the State agency to review and update its prior authorization process to improve communication with providers and thereby avoid or minimize delays that prevent members from receiving needed medical services.	CMS	–
We recommend that Amerigroup Iowa, Inc., coordinate with the State agency to improve its prior authorization and appeal processes to ensure that members receive correct information regarding prior authorizations, the appeal process, and State fair hearing rights, procedures, and timeframes.	CMS	–

Audit: A-04-22-07102
HHS Agency: CMS
Issued: 09/12/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Kentucky Cabinet for Health and Family Services, Department for Medicaid Services work with CMS to determine whether the other claims for multiple-source physician-administered drugs, totaling $5,967,128 ($4,281,678 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	$4,281,678
We recommend that the Kentucky Cabinet for Health and Family Services, Department for Medicaid Services file invoices for and collect from manufacturers rebates totaling $15,611,770 ($11,209,642 Federal share) for single-source and top-20 multiple-source physician-administered drugs and refund the Federal share of rebates collected.	CMS	$11,209,642
We recommend that the Kentucky Cabinet for Health and Family Services, Department for Medicaid Services ensure that all physician-administered drugs eligible for rebates after our audit period are processed for rebates.	CMS	–
We recommend that the Kentucky Cabinet for Health and Family Services, Department for Medicaid Services strengthen its internal controls to ensure that all eligible physician-administered drugs are invoiced for rebate.	CMS	–

Audit: A-07-23-00633
HHS Agency: CMS
Issued: 09/12/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that Novitas Solutions, Inc., work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare nonqualified costs of $84,291 for CYs 2016 through 2018.	CMS	$84,291

Audit: A-02-21-01005
HHS Agency: CMS
Issued: 09/11/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Puerto Rico Department of Health develop written policies and procedures to use sources other than the Puerto Rico Demographic Registry to identify deceased enrollees.	CMS	–
We recommend that the Puerto Rico Department of Health identify capitation payments made on behalf of enrollees with a date of death in the DMF before the month covered by the capitation payments, estimated as $885,123 in Federal Medicaid funds, and refund to the Federal Government the Federal share of any unallowable payment.	CMS	$885,123
We recommend that the Puerto Rico Department of Health develop written policies and procedures to ensure that DOH staff periodically update, at least monthly, DOH's eligibility system with data on deaths recorded in the Puerto Rico Demographic Registry.	CMS	–
We recommend that the Puerto Rico Department of Health establish a process with ASES to ensure ASES ceases making payments to MCOs on behalf of enrollees after their deaths are recorded in DOH's eligibility system and recoups unallowable payments made on behalf of deceased enrollees.	CMS	–
We recommend that the Puerto Rico Department of Health refund $6,979,822 to the Federal Government.	CMS	$6,979,822
We recommend that the Puerto Rico Department of Health identify capitation payments made after the audit period on behalf of deceased enrollees and refund to the Federal Government the Federal share of any unallowable payments.	CMS	–

Audit: A-02-21-02010
HHS Agency: SAMHSA
Issued: 09/11/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Substance Abuse and Mental Health Services Administration improve its policies and procedures for awarding CCBHC-E grants to ensure that clinics comply with Federal requirements by establishing required time frames to verify that clinics met certification eligibility requirements, and processes to verify whether clinics entered into agreements with DCOs to provide certain services.	SAMHSA	–
We recommend that the Substance Abuse and Mental Health Services Administration improve its policies and procedures for monitoring CCBHC-E grants to ensure that clinics comply with Federal requirements by establishing processes to verify that clinics filled key personnel positions, ensured key personnel met level-of-effort requirements, timely submitted FFRs, and properly reported cash on hand.	SAMHSA	–

Audit: A-02-21-01004
HHS Agency: CMS
Issued: 09/08/2023
Report link: Report pending

Recommendation text	Responsible agency	Potential savings
We recommend that the Puerto Rico Department of Health establish policies and procedures with the Puerto Rico Health Insurance Administration (referred to in Spanish with acronym ASES) to ensure ASES recovers unallowable payments made on behalf of enrollees assigned more than one identification number.	CMS	–
We recommend that the Puerto Rico Department of Health refund $516,762 to the Federal Government.	CMS	$516,762
We recommend that the Puerto Rico Department of Health strengthen its process for ensuring that no person is issued more than one identification number.	CMS	–

Audit: A-09-22-01000
HHS Agency: CDC
Issued: 09/08/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Centers for Disease Control and Prevention update its Provider Education, Assessment, and Reporting online system to include interactive reminders or alerts related to overdue site visits and followup actions.	CDC	–
We recommend that the Centers for Disease Control and Prevention work with program recipients to implement a plan and timeline to: (1) conduct the required site visits that are overdue and (2) verify the completion of followup actions that had not been completed by the deadlines.	CDC	–
We recommend that the Centers for Disease Control and Prevention complete the development and implementation of internal written policies and procedures for VFC program oversight activities, including oversight of program recipients' site visits to ensure that requirements are met.	CDC	–
We recommend that the Centers for Disease Control and Prevention develop an action plan to enforce site visit requirements by CDC's planned date of July 1, 2023.	CDC	–

Audit: A-09-23-03016
HHS Agency: CMS
Issued: 09/08/2023
Report link: Report pending

Recommendation text	Responsible agency	Potential savings
We recommend that the Centers for Medicare & Medicaid Services direct the MACs to recover from acute-care hospitals the portion of the $41,401,244 in identified overpayments for our audit period that are within the 4-year reopening period in accordance with CMS's policies and procedures.	CMS	$41,401,244
We recommend that the Centers for Medicare & Medicaid Services instruct the MACs to, based on the results of this audit, 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	–

Audit: A-04-22-06262
HHS Agency: ACF
Issued: 09/08/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that ACF develop mitigating controls and strategies to lower the high and moderate risks we identified.	ACF	–

Audit: A-04-22-08093
HHS Agency: CMS
Issued: 09/06/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Georgia Department of Community Health follow up with the 19 nursing homes 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 Georgia Department of Community Health develop a plan with CMS to address the foundational issues preventing more frequent surveys at nursing homes with a history of multiple high-risk deficiencies.	CMS	–
We recommend that the Georgia Department of Community 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 Georgia Department of Community Health work with CMS to develop standardized life safety training for nursing home staff.	CMS	–

Evaluation: OEI-05-22-00290
HHS Agency: CMS
Issued: 09/05/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
CMS should use data sources, in addition to OASIS assessments, to improve the accuracy of the quality measure related to falls with major injury.	CMS	–
CMS should ensure that HHAs submit required OASIS assessments when their patients are hospitalized.	CMS	–
CMS should explore whether improvements to the quality measure related to falls can also be used to improve the accuracy of other home health measures.	CMS	–
CMS should take steps to ensure the completeness and accuracy of the HHA-reported OASIS data used to calculate the falls with major injury quality measure.	CMS	–

Evaluation: OEI-06-22-00430
HHS Agency: MFCU
Issued: 09/05/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
Build upon its efforts to increase referrals of patient abuse or neglect.	OIG-MFCU	–
Implement a comprehensive case management system that allows for efficient access to case documents and information.	OIG-MFCU	–
Take steps to ensure that periodic supervisory reviews are conducted on a consistent basis and that case files i.nclude documentation of supervisory approvals.	OIG-MFCU	–
Continue efforts to hire a second-line supervisor and assess whether additional supervisors are warranted to meet the Unit's oversight needs.	OIG-MFCU	–

Audit: A-04-22-04089
HHS Agency: CMS
Issued: 08/31/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Florida Agency for Health Care Administration refund $106,153,061 to the Federal Government, representing the Federal share of rebates for calendar years 2015 through 2019 that the State agency did not refund.	CMS	$106,153,061

Evaluation: OEI-06-21-00150
HHS Agency: ACF
Issued: 08/28/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
OCSS should bolster State agency resilience during emergencies.	ACF	–
OCSS should create forums for identifying and sharing State agency best practices in providing paternity establishment services.	ACF	–

Audit: A-09-22-03005
HHS Agency: CMS
Issued: 08/17/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Centers for Medicare & Medicaid Services develop billing requirements for OTPs to include OUD diagnosis codes on claims for OUD treatment services to indicate that enrollees have OUD diagnoses, and consider working with MACs to implement a system edit to ensure that OTP payments are made for enrollees only when OUD diagnosis codes are included on claims.	CMS	–
We recommend that the Centers for Medicare & Medicaid Services work with MACs to provide education on proper billing of intake activities to the 8 OTPs that billed 14 or more intake activity claims per enrollee during our audit period.	CMS	–
We recommend that the Centers for Medicare & Medicaid Services work with MACs to determine whether claims billed by OTPs for OUD treatment services complied with Medicare requirements.	CMS	–
We recommend that the Centers for Medicare & Medicaid Services instruct MACs, based upon the results of this audit, to 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, up to $17,817,121, in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation.	CMS	$17,817,121
We recommend that the Centers for Medicare & Medicaid Services instruct MACs to implement edits in their claims processing systems to prevent an OTP from being paid for: (1) a weekly bundle with a service date that was within a contiguous 7-day period of another weekly bundle's service date for the same enrollee at the same OTP or (2) two weekly bundles with the same service date for the same enrollee at the same OTP.	CMS	–
We recommend that the Centers for Medicare & Medicaid Services revise its billing guidance to specify that OTPs should not bill add-on HCPCS codes for take-home supplies of medication for the same episode of care that was already covered by a weekly bundle that included medication, and instruct MACs to implement edits in their claims processing systems to identify improperly billed claims for take?home medication.	CMS	–

Audit: A-09-21-03020
HHS Agency: CMS
Issued: 08/09/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Centers for Medicare & Medicaid Services instruct Palmetto GBA to recover $72,208 in unallowable Medicare payments by adjusting the applicable OPOs' cost reports to correct the $148,750 of unallowable professional and public education overhead costs reported, consistent with relevant laws and the agency's policies and procedures.	CMS	$72,208
We recommend that the Centers for Medicare & Medicaid Services update applicable Medicare requirements to clarify which types of professional and public education overhead costs are unallowable (e.g., clarify whether the costs of meals provided to non-OPO employees for professional education and the costs of tickets to entertainment events purchased for the purpose of public education are unallowable), which could have saved Medicare an estimated $664,295 for professional and public education overhead costs during our audit period.	CMS	$592,087