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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

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Audit

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Showing 21–40 of 525 reports, containing 1,392 recommendations Sorted by most recent report

Audit: A-07-22-00621
HHS Agency: CMS
Issued: 01/05/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that National Government Services, Inc. decrease Medicare's share of the Plan B Medicare segment excess pension assets as of December 31, 2018, by $435,942 and recognize $374,464 as Medicare's share of the pension assets as a result of the benefit curtailment.	CMS	–
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. decrease the Plan B Medicare segment pension assets by $412,889 and recognize $14,107,153 as the Plan B Medicare segment pension assets as of December 31, 2018.	CMS	–

Audit: A-07-22-00620
HHS Agency: CMS
Issued: 01/05/2023
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that National Government Services, Inc. decrease Medicare's share of the Plan A Medicare segment excess pension liabilities as of December 31, 2018, by $47,508 and recognize $657,263 as Medicare's share of the pension liabilities as a result of the benefit curtailment.	CMS	$47,508
We recommend that National Government Services, Inc. increase the Plan A Medicare segment pension assets by $7,036 and recognize $8,296,591 as the Plan A Medicare segment pension assets as of December 31, 2018.	CMS	$7,036
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	–

Evaluation: OEI-03-21-00390
HHS Agency: CMS
Issued: 12/22/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
CMS should build a strategy to strengthen its internal controls for ensuring the accuracy of Part B drug payments.	CMS	–

Audit: A-07-19-01193
HHS Agency: CMS
Issued: 12/22/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that Cigna-HealthSpring of Tennessee, Inc. identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before and after our audit period and refund any resulting overpayments to the Federal Government.	CMS	–
We recommend that Cigna-HealthSpring of Tennessee, Inc. refund to the Federal Government the $5,987,509 of estimated overpayments.	CMS	$5,987,509
We recommend that Cigna-HealthSpring of Tennessee, Inc. continue its examination of 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	–

Evaluation: OEI-BL-21-00330
HHS Agency: CMS
Issued: 12/22/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
CMS should actively review current guidance related to the areas identified in this report and determine whether additional guidance would ensure more accurate and consistent ASP calculations.	CMS	–

Audit: A-05-21-00035
HHS Agency: CMS
Issued: 12/21/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the State agency establish a list of acceptable telehealth procedure codes.	MEDICAID STATE	–
We recommend that the State agency enhance the monitoring of provider compliance by conducting periodic reviews of telehealth payments for compliance with requirements.	MEDICAID STATE	–
We recommend that the State agency refund up to $9,832 to the Federal Government.	MEDICAID STATE	$9,832

Audit: A-04-20-02032
HHS Agency: ACF
Issued: 12/21/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
Develop and implement written policies and procedures to ensure that criminal background checks on employees are completed within required time frames.	ACF	–
Develop and implement procurement policies and procedures to avoid acquiring unnecessary items and to perform analyses to determine the most reasonable approach for future vehicle purchases.	ACF	–
Work with ACF to develop a viable plan for refunding $153,052 in unallowable costs to the Federal Government.	ACF	$153,052

Audit: A-07-22-00628
HHS Agency: CMS
Issued: 12/21/2022
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 the Medicare nonqualified costs of $657,765 for CYs 2015 through 2018.	CMS	$657,765

Audit: A-07-22-00625
HHS Agency: CMS
Issued: 12/21/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that National Government Services, Inc., work with CMS to revise its ICPs for CYs 2015 through 2018 to reduce its claimed SERP costs by $209,543.	CMS	$209,543

Audit: A-07-22-00624
HHS Agency: CMS
Issued: 12/21/2022
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 PRB costs of $636,197 for CYs 2015 through 2018.	CMS	$636,197

Audit: A-03-20-00201
HHS Agency: CMS
Issued: 12/20/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Pennsylvania Department of Human Services, Office of Medical Assistance Program, revise the initial denial notice template referenced under Exhibit N in the HealthChoices Agreement to include information regarding the beneficiary's right to request a State fair hearing after exhausting the MCO's appeals process.	CMS	–
Review all pediatric skilled nursing service requests for which overnight care was completely denied and determine whether the overnight care requests meet the medical necessity requirement regardless of whether the caregiver provided work or school verification documentation.	CMS	–
We recommend that Keystone First HealthChoices coordinate with the Pennsylvania Department of Human Services, Office of Medical Assistance Program, to update Keystone First's administrative process to require that medical directors assess whether overnight care requests meet the medical necessity requirement based on the documentation Keystone First has received even if some documentation, such as the caregiver's work verification documentation, is missing.	CMS	–
Implement a revised initial denial notice to explain that a beneficiary has the right to request a State fair hearing after exhausting the MCO's appeals process.	CMS	–

Audit: A-05-20-00031
HHS Agency: CMS
Issued: 12/20/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that CMS re-educate providers on the requirement for all home health claims to be submitted with the FIPS code for the county where the service was provided.	CMS	–
We recommend that CMS update the HH Pricer logic to check for missing and invalid FIPS codes on all home health claims and work with MACs to ensure that these claims are returned to providers for correction.	CMS	–

Audit: A-07-20-02825
HHS Agency: CMS
Issued: 12/15/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that CMS consider issuing instructions or guidance to the MACs that require or encourage more review of Medicare bad debts claimed in cost reports, such as defining thresholds beyond which individual Medicare bad debts would trigger an audit, and that directs the MACs to revise their cost report audit work plans accordingly.	CMS	–

Evaluation: OEI-07-18-00370
HHS Agency: CMS
Issued: 12/14/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
CMS should issue guidance to reiterate State obligations under the EPSDT benefit to ensure access to services to correct or ameliorate confirmed blood lead levels identified during screenings.	CMS	–
CMS should explore the discrepancy between Medicaid claims data and medical documentation for lead toxicity and implement solutions to ensure better oversight of the EPSDT program.	CMS	–

Evaluation: OEI-01-20-00241
HHS Agency: FDA
Issued: 11/29/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
FDA should collect data to support process and outcome measures for its oversight of online tobacco retailers.	FDA	–
FDA should collaborate with ATF on oversight of online tobacco retailers.	FDA	–
FDA should complete its rulemaking on non-face-to-face sales of tobacco products, as required by the Tobacco Control Act.	FDA	–
FDA should publish information and performance data on its oversight of online tobacco retailers.	FDA	–

Audit: A-06-20-04008
HHS Agency: CMS
Issued: 11/22/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
The Centers for Medicare & Medicaid Services should instruct the MACs to recoup $33,332 for ACP services paid in error for claims in our sample.	CMS	$33,332
The Centers for Medicare & Medicaid Services should educate providers on documentation and time requirements for ACP services to comply with Federal requirements. (That is, when another service is performed concurrently with a time-based service, the time associated with the concurrent service should not be included in the time used for reporting the time-based service, and time and ACP discussion must be documented). Had the requirements been followed, Medicare could have saved an estimated $42,266,931 during our audit period.	CMS	–
The Centers for Medicare & Medicaid Services should instruct the MACs, based on the results of this audit, to notify appropriate providers (i.e., those for whom CMS determines that this audit constitutes credible information of potential overpayments) so that the providers can exercise reasonable diligence in identifying, reporting, and returning 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 Centers for Medicare & Medicaid Services should establish Medicare requirements that address when it is appropriate to provide multiple ACP services for a single beneficiary and how these services should be documented when required to support the need for multiple services.	CMS	–

Audit: A-01-20-00503
HHS Agency: CMS
Issued: 11/22/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Centers for Medicare & Medicaid Services recover the portion of the $56,016 in Medicare Part B overpayments that are within the 4-year claim reopening period—including $31,545 in overpayments for the 69 incorrectly billed statistically sampled services and $24,471 in overpayments for the 62 incorrectly billed corresponding services.	CMS	$56,016
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	–
We recommend that the Centers for Medicare & Medicaid Services update its Medicare requirements and corresponding educational material to improve providers' understanding of the Medicare Part B billing requirements for co-surgery procedures, including: updating the Medicare Claims Processing Manual, chapter 12, section 40.8, to ensure billing providers understand that two physicians performing procedures as co-surgeons (including bilateral procedures) must append the co-surgery modifier regardless of whether they are in the same specialty or in different specialties, and providing additional education material to providers clarifying that spinal instrumentation procedure codes must be billed with a co-surgery modifier under Medicare Part B when performed as a co-surgery.	CMS	–
We recommend that the Centers for Medicare & Medicaid Services strengthen its system controls to detect and prevent improper payments to providers for incorrectly billed: (1) co-surgery services, (2) assistant-at-surgery services, and (3) duplicate services—which could have saved approximately $4,939,586 during our audit period.	CMS	$4,939,586

Audit: A-18-20-08005
HHS Agency: CMS
Issued: 11/18/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that the Puerto Rico Department of Health assess and adjust, if necessary, at least annually, the cryptographic configurations of public servers.	CMS	–
We recommend that the Puerto Rico Department of Health remediate the vulnerabilities related to the five security control findings identified by properly implementing and regularly assessing the associated NIST SP 800-53 controls.	CMS	–

Audit: A-06-21-08004
HHS Agency: CMS
Issued: 11/17/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that NGS collect $2,160,587 in lookback overpayments and return $22,576 in lookback refunds resulting from 2019 hospice cap calculations for lookback years.	CMS	$2,138,011
We recommend that NGS change its instructions on the cap determination notices to follow the CMS requirement that hospices remit overpayments at the time they submit their cap determination notice.	CMS	–
We recommend that NGS discontinue its internal policy of waiving certain overpayment collections related to lookback years and start collecting all hospice cap overpayments and paying refunds in accordance with CMS requirements.	CMS	–

Audit: A-01-20-00500
HHS Agency: CMS
Issued: 11/16/2022
Report link: View report

Recommendation text	Responsible agency	Potential savings
We recommend that Blue Cross & Blue Shield of Rhode Island 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 Blue Cross & Blue Shield of Rhode Island refund to the Federal Government the $4,894,595 of estimated net overpayments.	CMS	$4,894,595
We recommend that Blue Cross & Blue Shield of Rhode Island continue its examination of 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	–