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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 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—a subset that we think, if implemented, would have the most impact (learn more). Notable differences from our previous Top Unimplemented Recommendations report include:
- The list is comprised of individual recommendations from OIG reports, not rolled up by topic.
- No arbitrary cap is imposed on the number of recommendations included.
- Status updates as recommendations are implemented.
Summary of All Recommendations
Updated Monthly · Last updated on November 15, 2024
1,306
Unimplemented
recommendations
2,698
Implemented and Closed
recommendations since FY 2017
Views
OIG Recommendations Grouped by Report
-
Missouri Claimed Unallowable Federal Reimbursement for Some Medicaid Physician-Administered Drugs
15-A-07-115.01We recommend that the State agency refund to the Federal Government $34,181,807 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $34,181,807
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
15-A-07-115.02We recommend that the State agency refund to the Federal Government $656,150 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $656,150
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
15-A-07-115.03We recommend that the State agency work with CMS to determine the unallowable portion of the $13,225,151 (Federal share) for other claims for outpatient physician-administered drugs that were ineligible for Federal reimbursement and refund that amount.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
15-A-07-115.04We recommend that the State agency work with CMS to determine and refund the unallowable Federal reimbursement for physician-administered drugs claimed without NDCs and not billed for rebates after December 31, 2011.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
-
Novitas Solutions, Inc. (Formerly Highmark Medicare Services, Inc.), Did Not Always Refer Medicare Cost Reports and Reconcile Outlier Payments
15-A-05-107.01Review the 5 cost reports that had not been settled and should have been referred to CMS for reconciliation but were not, take appropriate actions to refer these cost reports, request CMS approval to recoup $11,477,187 in funds and associated interest from health care providers, and refund that amount to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $11,477,187
- Last Update Received
- -
- Closed Date
- 11/10/2021
- Legislative Related
- No
-
Maryland Misallocated Millions to Establishment Grants for a Health Insurance Marketplace
15-A-01-105.01We recommend that the State agency refund $15.9 million to CMS that was misallocated to the establishment grants by not prospectively using updated actual enrollment data.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $15,900,000
- Last Update Received
- -
- Next Update Expected
- 09/26/2022
- Legislative Related
- No
15-A-01-105.02We recommend that the State agency refund $12.5 million to CMS that was misallocated to the establishment grants using a methodology that included a material defect.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- $12,500,000
- Last Update Received
- -
- Next Update Expected
- 09/26/2022
- Legislative Related
- No
15-A-01-105.03We recommend that the State agency develop a written policy that explains how to calculate cost allocations and that emphasizes the necessity to use updated and actual data.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 09/26/2022
- Legislative Related
- No
15-A-01-105.04We recommend that the State agency immediately amend the CAP and the APD for the period July 1 through December 31, 2014, so that allocated costs correspond to the relative benefits received.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 09/26/2022
- Legislative Related
- No
15-A-01-105.05We recommend that the State agency oversee operations to ensure (1) the identification and correction of enrollment projection errors, (2) the use of better or updated enrollment data, and (3) the application of these data to allocate costs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 09/26/2022
- Legislative Related
- No
-
National Government Services, Inc., Did Not Always Refer Medicare Cost Reports and Reconcile Outlier Payments in Jurisdiction 8
15-A-05-099.03Review the 6 cost reports that were referred to CMS and had outlier payments that qualified for reconciliation and work with CMS to reconcile the $10,855,073 in associated outlier payments due to the Federal Government, finalize these cost reports, and ensure that the providers return the funds to Medicare.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $10,855,073
- Last Update Received
- -
- Closed Date
- 10/02/2021
- Legislative Related
- No
-
Medicare Could Have Saved Billions at Critical Access Hospitals If Swing-Bed Services Were Reimbursed Using the Skilled Nursing Facility Prospective Payment System Rates
15-A-05-094.01We recommend that CMS seek legislation to adjust CAH swing-bed reimbursement rates to the lower SNF PPS rates paid for similar services at alternative facilities.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 09/09/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
-
New York State Improperly Claimed Medicaid Reimbursement for Continuous 24-Hour Personal Care Claims in Ulster County
15-A-02-093.01We recommend that the State agency refund $6,276,189 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $6,276,189
- Last Update Received
- 03/25/2024
- Next Update Expected
- 09/25/2024
- Legislative Related
- No
-
Not All Children in Foster Care Who Were Enrolled in Medicaid Received Required Health Screenings
15-E-07-020.01ACF should expand the scope of the Child and Family Services Reviews to determine whether children in foster care receive required health screenings according to the timeframes specified in States' plans.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/16/2023
- Legislative Related
- No
-
New York State Improperly Claimed Medicaid Reimbursement for Continuous 24-Hour Personal Care Claims
15-A-02-086.01The State agency should refund $12,063,508 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $12,063,508
- Last Update Received
- 10/07/2024
- Next Update Expected
- 04/07/2025
- Legislative Related
- No
-
Acute-Care Hospitals in Ohio Did Not Always Reconcile Invoice Records With Credit Balances and Refund the Associated Medicaid Overpayments to the State Agency
15-A-05-071.01We recommend that the State agency refund $26,426 to the Federal Government for overpayments paid to the selected hospitals.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $26,426
- Last Update Received
- 07/31/2015
- Next Update Expected
- 07/30/2022
- Legislative Related
- No
15-A-05-071.02We recommend that the State agency enhance its efforts to recover additional overpayments estimated at $4,630,721 ($3,048,126 Federal share) from our audit period and realize future savings by requiring hospitals to reconcile invoice records with credit balances and reporting the associated Medicaid overpayments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $3,048,126
- Last Update Received
- 08/13/2018
- Next Update Expected
- 07/30/2022
- Legislative Related
- No
-
Federal Marketplace: Inadequacies in Contract Planning and Procurement
15-E-03-014.06HHS should revise its guidance to include specific standards for conducting past performance reviews of companies under consideration during contract procurement.- Status
- Open Unimplemented
- Responsible Agency
- ASFR
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 04/17/2023
- Next Update Expected
- 05/18/2024
- Legislative Related
- No
-
The University of California at Irvine's Pilot Payroll Certification System Could Not Be Assessed
15-A-04-041.01We recommended that the University reconcile the $491,291,290 it reported on its FFRs to its accounting records.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- $491,291,290
- Last Update Received
- -
- Closed Date
- 03/28/2022
- Legislative Related
- No
15-A-04-041.02We recommended that the University modify its financial management system to ensure that amounts it reports on its FFRs can be supported by amounts recorded in its accounting records.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/28/2022
- Legislative Related
- No
-
Access to Care: Provider Availability in Medicaid Managed Care
15-E-02-009.01CMS should work with States to assess the number of providers offering appointments and improve the accuracy of plan information.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/12/2022
- Legislative Related
- No
15-E-02-009.02CMS should work with States to ensure that plans' networks are adequate and meet the needs of their Medicaid managed care enrollees.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/12/2022
- Legislative Related
- No
15-E-02-009.03CMS should work with States to ensure that plans are complying with existing State standards and assess whether additional standards are needed.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/12/2022
- Legislative Related
- No
-
New Jersey Claimed Excessive Medicaid Disproportionate Share Hospital Payments for Five County-Operated Psychiatric Facilities
15-A-02-026.01We recommend that the State agency refund $11,855,610 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $11,855,610
- Last Update Received
- 09/26/2024
- Next Update Expected
- 03/30/2025
- Legislative Related
- No
-
Missouri Claimed Unallowable Medicaid Payments for Targeted Case Management Services Provided to Individuals With Developmental Disabilities
15-A-07-019.01We recommend that the State agency refund $11,464,069 to the Federal Government, adjust future payment rates for TCM services and work with the Centers for Medicare & Medicaid Services to determine the unallowable Medicaid payments that should be refunded to the Federal Government, and follow the State plan requirements for the calculation of rebased payment rates for TCM services.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $11,464,069
- Last Update Received
- 09/27/2024
- Next Update Expected
- 03/27/2025
- Legislative Related
- No
15-A-07-019.02We recommend that the State agency adjust future payment rates for TCM services and work with the Centers for Medicare & Medicaid Services to determine the unallowable Medicaid payments that should be refunded to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/27/2024
- Next Update Expected
- 03/27/2025
- Legislative Related
- No
-
Texas Did Not Always Comply With Federal and State Requirements for Claims Submitted for the Nonemergency Medical Transportation Program
15-A-06-008.01We recommend that the State agency refund $30,385,925 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $30,385,925
- Last Update Received
- 03/21/2024
- Next Update Expected
- 01/01/2025
- Legislative Related
- No
-
Medicare Beneficiaries Paid Nearly Half of the Costs for Outpatient Services at Critical Access Hospitals
15-E-05-001.01CMS should seek legislative authority to modify how coinsurance is calculated for outpatient services received at Critical Access Hospitals.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/08/2024
- Next Update Expected
- 07/01/2024
- Legislative Related
- Yes
-
State Standards for Access to Care in Medicaid Managed Care
14-E-02-078.01CMS should strengthen its oversight of State standards and ensure that States develop standards for key providers.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/17/2023
- Legislative Related
- No
14-E-02-078.02CMS should strengthen its oversight of States' methods to assess plan compliance and ensure that States conduct direct tests of access standards.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/17/2023
- Legislative Related
- No
14-E-02-078.03CMS should improve States' efforts to identify and address violations of access standards.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/17/2023
- Legislative Related
- No
-
Medicare Part B Prescription Drug Dispensing and Supplying Fee Payment Rates Are Considerably Higher Than the Rates Paid by Other Government Programs
14-A-06-280.01We recommend that CMS amend current regulations to decrease the Part B payment rates for dispensing and supplying fees to rates similar to those of other payers, such as Part D and Medicaid.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/20/2023
- Legislative Related
- No
-
CMS Has Yet To Enforce a Statutory Provision Related to Rural Health Clinics
14-E-05-074.01CMS should issue regulations to ensure that RHCs determined to be essential providers remain certified as RHCs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 04/29/2024
- Next Update Expected
- 07/02/2025
- Legislative Related
- No
-
The District of Columbia Claimed Unallowable Federal Reimbursement for Some Medicaid Physician-Administered Drugs
14-A-03-263.01We recommend the State Agency refund to the Federal Government $2,392,539 (Federal share) for single-source and top-20 multiple-source physician-administered drug claims that were ineligible for Federal reimbursement.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $2,392,539
- Last Update Received
- -
- Closed Date
- 11/01/2021
- Legislative Related
- No
14-A-03-263.03We recommend the State agency work with CMS to determine and refund the unallowable Federal reimbursement for physician-administered drugs claimed without NDCs after January 1, 2011.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/17/2024
- Legislative Related
- No
14-A-03-263.04We recommend the State agency ensure that its MMIS edits require valid NDCs for payment on all drug claims.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
14-A-03-263.05We recommend that the State agency improve its rebate processes to ensure that all physician-administered drug claims are submitted for rebates.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No