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. In OIG’s view, these top recommendations for HHS programs, if implemented, would have the greatest impact in terms of cost savings, program effectiveness and efficiency, and public health and safety. Learn more
Summary of All Recommendations
Updated Monthly · Last updated on Sept. 11, 2026
1,051
Unimplemented
recommendations
3,529
Implemented and Closed
recommendations since FY 2017
Views
OIG Recommendations Grouped by Report
-
Florida Medicaid Fraud Control Unit: 2025 Inspection
26-E-06-028.01Build upon its efforts to improve the quality of referrals from its primary referral sources.- Status
- Open Unimplemented
- Responsible Agency
- MFCU
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/29/2026
- Legislative Related
- No
26-E-06-028.02Take steps to ensure that it reports all adverse actions to the NPDB within the required timeframe.- Status
- Open Unimplemented
- Responsible Agency
- MFCU
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/29/2026
- Legislative Related
- No
26-E-06-028.03Update its training plan to include annual minimum training hour requirements for each professional discipline.- Status
- Open Unimplemented
- Responsible Agency
- MFCU
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/29/2026
- Legislative Related
- No
-
Medicare Could Have Saved $255.1 Million Related to Hospice Services for Certain New Hospice Enrollees
26-A-06-077.01We recommend that CMS work with the hospice MACs to consider this high-risk area in their hospice eligibility reviews and to possibly develop pre- or postpayment review procedures for new hospice enrollees without an inpatient or emergency room claim 18 months prior to starting hospice care, which could have saved an estimated $255.1 million in hospice claim payments during our audit period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- $255,113,489
- Last Update Received
- -
- Next Update Expected
- 12/17/2026
- Legislative Related
- No
-
CMS’s Processes Were Not Effective in Ensuring the Accuracy of Staffing Information Reported in the Payroll-Based Journal
26-A-09-076.01We recommend that CMS consider the results of our audit when selecting nursing homes for followup audits by the CMS PBJ auditor.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 07/20/2026
- Next Update Expected
- 02/06/2027
- Legislative Related
- No
26-A-09-076.02We recommend that CMS require the CMS PBJ auditor to verify whether nursing homes have taken corrective actions on findings identified in prior PBJ audits.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/16/2026
- Legislative Related
- No
26-A-09-076.03We recommend that CMS educate nursing homes on the updated guidance available in the PBJ Policy Manual and PBJ Policy Manual FAQs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 07/20/2026
- Next Update Expected
- 02/06/2027
- Legislative Related
- No
26-A-09-076.04We recommend that CMS regularly communicate to nursing homes the trends in CMS PBJ audit findings (e.g., by providing information on frequently identified CMS PBJ audit findings during an Open Door Forum and on the PBJ web page).- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 07/20/2026
- Next Update Expected
- 02/06/2027
- Legislative Related
- No
-
Jefferson Regional Medical Center Received at Least $4.7 Million in Medicare Overpayments
26-A-04-074.01We recommend that the Hospital refund to the Federal government the estimated $4,701,168 in net overpayments for incorrectly billed claims, excluding amounts presumed to be unrecoverable under the Section 1870 waiver of liability provision.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- $4,701,168
- Last Update Received
- -
- Next Update Expected
- 12/15/2026
- Legislative Related
- No
26-A-04-074.02We recommend that the Hospital consider conducting one or more internal audits or investigations for claims after our audit period, based on the risks identified by this audit, to identify any similar overpayments the Hospital might have received and return any identified overpayments to the Medicare program.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/15/2026
- Legislative Related
- No
26-A-04-074.03We recommend that the Hospital provide additional training to clinical and billing personnel on its policies and procedures related to the Two-Midnight Rule, IRF admissions requirements, and inpatient and outpatient coding.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/15/2026
- Legislative Related
- No
-
North Dakota Could Better Ensure That Providers Fully Comply With Federal Waiver and State Health, Safety, and Administrative Requirements at 44 Residential Settings
26-A-07-075.01We recommend that the North Dakota Department of Health and Human Service's Developmental Disability Section follow up with the residential providers that had the 182 instances of provider noncompliance identified in this report to ensure that they have taken corrective actions.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/15/2026
- Legislative Related
- No
26-A-07-075.02We recommend that the North Dakota Department of Health and Human Service's Developmental Disability Section improve oversight and monitoring of residential providers to better identify and address health and safety risks.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/15/2026
- Legislative Related
- No
26-A-07-075.03We recommend that the North Dakota Department of Health and Human Service's Developmental Disability Section work with the residential providers to improve internal controls for health and safety at residential settings, maintenance of records, and training.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/15/2026
- Legislative Related
- No
-
Inaccurate Medicaid Managed Care Provider Directories May Limit Enrollees’ Access to Maternal Health Care
26-E-05-027.01CMS should take steps to support States in holding Medicaid managed care plans accountable for the accuracy of their online provider directories.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/10/2026
- Legislative Related
- No
-
Inaccurate Medicaid Managed Care Network Lists May Compromise State Oversight of Access to Maternal Health Care
26-E-05-026.01CMS should work with States to improve the accuracy of the provider data they use to evaluate the adequacy of networks in Medicaid managed care.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/10/2026
- Legislative Related
- No
26-E-05-026.02CMS should take steps to support States in holding Medicaid managed care plans accountable for the accuracy of the network lists used for assessing network adequacy.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/10/2026
- Legislative Related
- No
-
The Three Largest Medicare Advantage Organizations Denied Requests for Long-Term Acute Care and Inpatient Rehabilitation at Some of the Highest Rates
26-E-09-023.01CMS should regularly collect request-level prior authorization data that include standardized service type and contractor information.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-E-09-023.02CMS should assess reasons for the wide variation in LTCH and IRF denial and overturn rates across MAOs and contractors and take action as appropriate.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
-
Medicare Advantage Organizations Overturned Nearly All Appealed Prior Authorization Denials for Skilled Nursing Facility Admission, Raising Concerns About Initial Denials
26-E-09-024.01CMS should take action to address any breakdowns in the initial reviews of SNF admission requests that are driving the extremely high overturn rate of SNF admission denials.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-E-09-024.02CMS should assess the reasons for variation in SNF denial rates across MAOs and contractors and take action as appropriate.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-E-09-024.03CMS should assess reasons for the differences in SNF denial rates between nursing home residents and other enrollees and take action as warranted.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
-
California Made at Least $13.9 Million More in Medicaid Reimbursements for Clinical Diagnostic Laboratory Services Than Was Allowed by Federal and State Requirements
26-A-01-071.01We recommend that the State agency refund $7,576,103 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- $7,576,103
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-01-071.02We recommend that the State agency work with CMS to determine whether potential overpayments of $16,477,416 (Federal share) complied with Federal and State requirements and refund the Federal share of any overpayments to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-01-071.03We recommend the State agency review payments made after our audit period to identify any additional overpayments and refund the Federal share to the Federal Government. Additionally, the State agency should clearly identify any additional overpayments refunded as having been made in accordance with this recommendation.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-01-071.04We recommend that the State agency evaluate and strengthen its existing policies and procedures for reviewing and updating rates in its claims processing system to ensure that the amounts claimed for clinical diagnostic laboratory services do not exceed the amount that would be paid under the Medicare program or the amounts allowed by State requirements.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
-
Community Behavioral Health Did Not Comply With Requirements When Denying Prior Authorization Requests
26-A-03-072.01We recommend that CBH update its policies and procedures to include: (1) a requirement to reconcile discrepancies between addresses of record and addresses given to treatment providers and (2) a process for determining when a change of residency occurs and notifying the CAO accordingly.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-03-072.02We recommend that CBH implement a process for identifying service requests that are considered approved because a decision notification was not sent within the 21-day window.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-03-072.03We recommend that CBH coordinate with the State agency to implement a revised initial denial notice that informs enrollees that they have the right to be provided, upon request and free of charge, all documents, records, and other information relevant to the adverse benefit determination as required by 42 CFR section 438.404(b)(2).- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-03-072.04We recommend that CBH revise the language it uses in the denial notice to clarify when services are denied as requested but CBH recommends alternate services that do not require a prior authorization, as opposed to services being completely denied with no alternate services recommended.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-03-072.05We recommend that CBH update its policies to comply with its HealthChoices Agreement by requiring staff to document the following for enrollees under 21 years of age: (1) steps taken to contact the enrollee's representative to request that the enrollee's representative ask the provider to communicate with CBH, and (2) efforts to reach the provider before issuing denial notices.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
26-A-03-072.06We recommend that the State agency revise the denial notice template in the HealthChoices Agreement to include a statement that the enrollee has the right to be provided, upon request and free of charge, all documents, records, and other information relevant to the adverse benefit determination.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/07/2026
- Legislative Related
- No
-
The Office of Refugee Resettlement Needs To Improve Its Monitoring of Unlicensed Unaccompanied Alien Children Program Care Providers’ Compliance With Background Check Requirements
26-A-06-070.01We recommend that ORR conduct required abbreviated monitoring visits at unlicensed facilities approximately every 90 days.- Status
- Open Unimplemented
- Responsible Agency
- ACF
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/04/2026
- Legislative Related
- No
26-A-06-070.02We recommend that ORR put mechanisms in place to verify that all required background checks at unlicensed care providers are conducted.- Status
- Open Unimplemented
- Responsible Agency
- ACF
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/04/2026
- Legislative Related
- No
-
Lehigh Valley Hospital Received At Least $17.8 Million in Medicare Overpayments
26-A-03-069.01We recommend that the Hospital refund to the Federal government the estimated $17,838,422 in net overpayments for incorrectly billed claims, excluding amounts presumed to be unrecoverable under the Section 1870 waiver of liability provision.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- $17,838,422
- Last Update Received
- -
- Next Update Expected
- 12/03/2026
- Legislative Related
- No
26-A-03-069.02We recommend that the Hospital consider conducting one or more internal audits or investigations for claims beyond our audit period, based on the risks identified by this audit, to identify any similar overpayments the Hospital might have received and return any identified overpayments to the Medicare program.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/03/2026
- Legislative Related
- No
26-A-03-069.03We recommend that the Hospital provide additional training to clinical and billing personnel on its policies and procedures related to the following: Two-Midnight Rule; the medical necessity of inpatient services; IRF admissions; IRF documentation requirements ; and Inpatient and outpatient coding.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/03/2026
- Legislative Related
- No
-
CMS Should Improve Its Policies and Procedures for the Oversight of States’ Reported Medicaid Expenditures to Better Protect the Financial Integrity of the Medicaid Program
26-A-06-068.01We recommend that CMS develop and implement additional training for analysts to improve the clarity, accuracy, and consistency of their documentation for reviewing CMS-64s.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/02/2026
- Legislative Related
- No
26-A-06-068.02We recommend that CMS revise its policies and procedures related to deferred payments to align the deferral resolution timelines with Federal regulations.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/02/2026
- Legislative Related
- No
26-A-06-068.03We recommend that CMS modify its policies and procedures to specify which CMS departments are responsible for tracking and resolving disallowed payments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/02/2026
- Legislative Related
- No
26-A-06-068.04We recommend that CMS modify its Review Guide to include a step that requires analysts to determine the status of disallowed payments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 12/02/2026
- Legislative Related
- No
-
CMS Potentially Overpaid Medicare Advantage Organizations $462 Million Based on Certain Unsupported Acute Stroke Diagnosis Codes
26-A-02-067.01We recommend that CMS implement a procedure to prevent overpayments to MA organizations when acute stroke diagnosis codes are submitted by MA organizations on a physician data record and the enrollee does not have an acute stroke diagnosis on an inpatient or outpatient hospital data record during the same service year (e.g., CMS filter of EDS data to identify and address these diagnosis codes or instructions to MA organizations to implement a control to prevent the submission of these diagnosis codes), which could have resulted in cost savings of $462 million.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- $461,958,186
- Last Update Received
- -
- Next Update Expected
- 11/27/2026
- Legislative Related
- No
-
Connecticut Did Not Always Ensure Selected Nursing Homes Complied With Federal and State Background Check Requirements
26-A-01-066.01We recommend that DPH strengthen its monitoring activities to ensure that nursing homes comply with requirements that prohibit the employment of individuals with disqualifying backgrounds, such as expanding the timeframe covered by recertification surveys.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/07/2026
- Legislative Related
- No
26-A-01-066.02We recommend that DPH ensure that all required background checks have been conducted for the 9 selected nursing homes that employ the 46 individuals in our sample who were missing 1 or more background checks.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/07/2026
- Legislative Related
- No
26-A-01-066.03We recommend that DPH ensure that all training materials on how to conduct background checks for new employees are made available to nursing homes.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/07/2026
- Legislative Related
- No
-
Unclear Medicare Requirements Led to Differing Interpretations of Inpatient Rehabilitation Facility Documentation, Coverage, and Billing Requirements
26-A-04-065.01We recommend that CMS revise or clarify IRF documentation requirements related to the: (1) development and individualization of the POC, (2) leadership of IDT meetings by rehabilitation physicians, (3) review at IDT meetings of enrollee progress toward rehabilitation goals and identification of any problems that could impede such progress, and (4) functional status of enrollees during the preadmission screening.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/11/2026
- Legislative Related
- No
26-A-04-065.02We recommend that CMS revise or clarify IRF coverage requirements to define: (1) what constitutes a reasonable expectation that an enrollee requires supervision by a rehabilitation physician, (2) what it means to have active and ongoing therapeutic intervention from multiple disciplines, and (3) what it means to be sufficiently stable to actively participate in an intensive rehabilitation therapy program.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/11/2026
- Legislative Related
- No
26-A-04-065.03We recommend that CMS revise or clarify IRF-PAI signature requirements.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 06/03/2026
- Next Update Expected
- 12/04/2026
- Legislative Related
- No
26-A-04-065.04We recommend that CMS offer training and learning sessions to assist IRFs with regulation compliance.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/11/2026
- Legislative Related
- No
-
Utilization Trends and Medicare Part B Billing for Office-Based Peripheral Vascular Procedures Raise Questions About Program Integrity
26-E-01-021.01CMS should monitor billing to identify peripheral vascular procedures that may be medically unnecessary, which may indicate fraud, waste, or abuse.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 11/03/2026
- Legislative Related
- No
26-E-01-021.02CMS should follow up on the physicians OIG identified with concerning billing for peripheral vascular procedures.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/10/2026
- Next Update Expected
- 11/03/2026
- Legislative Related
- No
-
Most Nursing Homes Throughout the United States Do Not Have Adequate or Reliable Emergency Power Systems
26-A-02-064.01We recommend that CMS share the results of this report with nursing homes and emphasize the importance of having adequate and reliable emergency power systems.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/11/2026
- Legislative Related
- No
-
Medicare Payments for Positive Airway Pressure Devices Used for the Treatment of Obstructive Sleep Apnea Generally Complied With Medicare Requirements
26-A-05-063.01We recommend that CMS establish and implement internal controls to prevent improper payments for replacement PAP devices, which amounted to an estimated $15.2 million for our audit period.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 10/22/2026
- Legislative Related
- No
26-A-05-063.02We recommend that CMS provide outreach and education to suppliers on coverage requirements for PAP devices used in treating OSA to prevent improper payments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Not Yet Due
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 10/22/2026
- Legislative Related
- No