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 December 17, 2025
1,189
Unimplemented
recommendations
3,163
Implemented and Closed
recommendations since FY 2017
Views
OIG Recommendations Grouped by Report
-
New York Misallocated Costs to Establishment Grants for a Health Insurance Marketplace
17-A-02-028.01We recommend that the State agency amend its CAP for the period August 2011 through March 2014 and either refund $93,393,879 to CMS that was allocated to the establishment grants using a methodology that included a material defect or work with CMS to determine the appropriate allocation to the establishment grants.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $93,393,879
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-02-028.02We recommend that the State agency refund to CMS $55,261,734, consisting of $49,493,613 that was misallocated to the establishment grants by not using updated, better data and $5,768,121 that was misallocated to the establishment grants for in-person enrollment assistance costs that also benefited Medicaid, or work with CMS to resolve the amounts misallocated to the establishment grants.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $55,261,734
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-02-028.03We recommend that the State agency refund to CMS $998,899 for costs that were incurred after the funding period had ended on an establishment grant.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $998,899
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-02-028.04We recommend that the State agency work with CMS to ensure that costs claimed after our audit period are allocated correctly using an updated cost allocation methodology.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-02-028.05We recommend that the State agency amend the CAP and the Advance Planning Documents for the period April 1 through December 31, 2014, to reflect the updated cost allocation methodology.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-02-028.06We recommend that the State agency develop a written policy that explains how to perform cost allocations and emphasizes the necessity to use updated, better data when available.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-02-028.07We recommend that the State agency ensure application of updated, better data to properly allocate costs and proper allocation of costs for all allocable project components.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-02-028.08We recommend that the State agency follow established procedures to ensure that only costs resulting from obligations of the funding period are claimed for Federal reimbursement.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
-
North Carolina Improperly Claimed Federal Reimbursement for Some Medicaid Nonemergency Transportation Services
17-A-04-027.01We recommended that the State agency refund $12,011,228 to the Federal Government for unallowable NEMT services identified in our sample.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $12,011,228
- Last Update Received
- -
- Closed Date
- 04/13/2022
- Legislative Related
- No
17-A-04-027.02We recommended that the State agency refund $3,121,544 to the Federal Government for the additional Federal reimbursement received for NEMT expenditures improperly claimed at the FMAP rate.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $3,121,544
- Last Update Received
- -
- Closed Date
- 04/13/2022
- Legislative Related
- No
-
Wisconsin Physicians Service Insurance Corporation Did Not Properly Settle Indiana Medicare Disproportionate Share Hospital Cost Report Payments
17-A-07-020.01We recommend that WPS revise the finalized Medicare cost report settlements to recover $6,110,557 in Medicare DSH overpayments from the 48 selected Indiana providers and refund that amount to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $6,110,557
- Last Update Received
- -
- Closed Date
- 12/14/2021
- Legislative Related
- No
-
New York Made Some Incorrect Medicaid Electronic Health Record Incentive Payments
17-A-02-010.03We recommend that the State agency review the incentive payment calculations for the hospitals not included in the 30 we reviewed to determine whether payment adjustments are needed, and refund any overpayments identified.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/16/2022
- Legislative Related
- No
-
Indian Health Service Hospitals: More Monitoring Needed to Ensure Quality Care
17-E-06-001.01IHS should implement a quality-focused compliance program to support Federal requirements for health care programs.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/07/2025
- Legislative Related
- No
17-E-06-001.02IHS should establish standards and expectations for how Area Offices/ Governing Boards oversee and monitor hospitals and monitor adherence to those standards.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/06/2023
- Legislative Related
- No
17-E-06-001.03IHS should continue to seek new meaningful ways to monitor hospital quality through the use of outcomes and/or process measures.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/07/2025
- Legislative Related
- No
17-E-06-001.04IHS should continue to invest in training for hospital administration and staff, and assess the value and effectiveness of training efforts.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/06/2023
- Legislative Related
- No
17-E-06-001.05CMS should assist IHS in its oversight efforts by conducting more frequent surveys of hospitals, informing IHS leadership of deficiency citations, and continuing to provide technical assistance and training.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/30/2025
- Legislative Related
- No
-
Indian Health Service Hospitals: Longstanding Challenges Warrant Focused Attention to Support Quality Care
17-E-06-002.02IHS should conduct a needs assessment culminating in an agencywide strategic plan with actionable initiatives and target dates.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/25/2023
- Legislative Related
- No
-
Not All Internal Controls Implemented by CDC Were Effective in Ensuring That World Trade Center Health Program Pharmacy and Medical Claims Were Paid According to Federal Requirements
16-A-02-219.01We recommend that CDC establish a procedure for collecting and transmitting NY Metro area members' prescription drug insurance coverage information to PBMs for benefits coordination.- Status
- Closed Implemented
- Responsible Agency
- CDC
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/25/2022
- Legislative Related
- No
-
California Made Incorrect Medicaid Electronic Health Record Incentive Payments to Hospitals
16-A-09-215.03We recommend that the State agency review the calculations for the hospitals not included in the 64 we reviewed to determine whether payment adjustments are needed and refund to the Federal Government any overpayments identified.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $5,650,820
- Last Update Received
- -
- Closed Date
- 04/14/2022
- Legislative Related
- No
-
Vermont Did Not Properly Allocate Millions to Establishment Grants for a Health Insurance Marketplace
16-A-01-213.01We recommend that the State agency amend its CAP for July 2012 through September 2013 and either refund $10.5 million to CMS that was allocated to the establishment grants using a methodology that included a material defect or work with CMS to determine the appropriate allocation to the establishment grants.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $10,506,676
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
16-A-01-213.02We recommend that the State agency use the actual enrollment data for April through September 2014 to determine the appropriate allocation to the establishment grants, work with CMS to determine what portion of $13.9 million was properly allocated to the establishment grants, and refund any portion that was not properly allocated.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
16-A-01-213.03We recommend that the State agency reduce establishment grant drawdowns after our audit period or refund $736,330 to CMS that was overdrawn in establishment grants as of September 30, 2014.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $736,330
- Last Update Received
- -
- Closed Date
- 08/29/2025
- Legislative Related
- No
16-A-01-213.04We recommend that the State agency develop policies and procedures that explain how to develop a CAP based on the relative benefits received and when to reassess and revise the CAP and related allocations on a retroactive or prospective basis.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
16-A-01-213.05We recommend that the State agency ensure that procedures are in place and the updated policies are followed for the reconciliation of reported grant expenditures and drawdowns to cumulative actual spending.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
-
Hospices Should Improve Their Election Statements and Certifications of Terminal Illness
16-E-02-046.04CMS should provide guidance to hospices regarding the effects on beneficiaries when they revoke their election and when they are discharged from hospice care.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/24/2024
- Next Update Expected
- 10/25/2025
- Legislative Related
- No
-
Washington State Claimed Federal Medicaid Reimbursement for Inpatient Hospital Services Related to Treating Provider-Preventable Conditions
16-A-09-198.01We recommend that the State agency work with CMS to determine what portion of the $10,842,919 Federal share claimed was unallowable for Federal Medicaid reimbursement and refund to the Federal Government the unallowable amount.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $199,898
- Last Update Received
- -
- Closed Date
- 10/15/2021
- Legislative Related
- No
16-A-09-198.02We recommend that the State agency review all paid claims before our audit period for inpatient hospital services with dates of admission from January 1, 2010, through June 30, 2012, to determine whether payments should be adjusted for any claims that contained PPCs and a POA code indicating that the condition was not present on admission; a POA code indicating that the documentation in the patient's medical record was insufficient to determine whether the condition was present on admission; or no POA code.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/15/2021
- Legislative Related
- No
16-A-09-198.03We recommend that the State agency refund to the Federal Government its share of any unallowable amounts for those paid claims reviewed.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/15/2021
- Legislative Related
- No
-
Medicare Compliance Review of North Carolina Baptist Hospital for Claims Paid From January 1, 2013, Through August 31, 2014
16-A-04-197.02We recommended that the hospital strengthen controls to ensure full compliance with Medicare requirements.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
16-A-04-197.03We recommended that the hospital exercise reasonable diligence to identify and return any additional overpayments received outside of our audit period, in accordance with the 60-day repayment rule.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
-
New Jersey Made Incorrect Medicaid Electronic Health Record Incentive Payments
16-A-02-190.01We recommend that the State agency refund to the Federal government $2,270,213 in net overpayments made to 15 hospitals.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $2,270,213
- Last Update Received
- -
- Closed Date
- 10/25/2021
- Legislative Related
- No
-
Medicare Compliance Review of Home Health VNA for 2011 and 2012
16-A-01-187.01We recommend that the Agency refund to the Medicare contractor $6,348,971 in estimated overpayments for claims incorrectly billed that are within the 3-year recovery period.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $6,348,971
- Last Update Received
- -
- Closed Date
- 11/16/2021
- Legislative Related
- No
-
MACs Continue to Use Different Methods to Determine Drug Coverage
16-E-03-037.01CMS should assign a single entity to assist MACs with making coverage determinations.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/22/2024
- Legislative Related
- No
-
Texas Did Not Always Comply With Federal Requirements and Its Cost Allocation Plan When It Claimed Medicaid Administrative Costs
16-A-06-173.02We recommend that the State Agency ensure that the method the State agency uses to allocate the indirect costs is consistent with the approved PACAP.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
-
FDA is Issuing More Postmarketing Requirements, but Challenges with Oversight Persist
16-E-01-035.01FDA should provide a standardized form for Annual Status Reports (ASRs), ensure that they are complete, and require sponsors to submit them electronically.- Status
- Closed Implemented
- Responsible Agency
- FDA
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/28/2024
- Legislative Related
- No
16-E-01-035.02FDA should build capacity in the Document Archiving, Reporting, and Regulatory Tracking System (DARRTS) to support postmarketing requirements (PMR) oversight.- Status
- Closed Implemented
- Responsible Agency
- FDA
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/28/2024
- Legislative Related
- No
-
Adverse Events in Rehabilitation Hospitals: National Incidence Among Medicare Beneficiaries
16-E-06-034.03CMS should include information about potential events and patient harm in its quality guidance to rehab hospitals.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 01/08/2025
- Legislative Related
- No
-
Medicare Compliance Review of Excellent Home Care Services, LLC
16-A-02-169.01We recommend that the Agency refund to the Medicare contractor $6,382,323 in estimated net overpayments for claims incorrectly billed that are within the 3-year claims recovery period.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $1,531,015
- Last Update Received
- -
- Closed Date
- 11/01/2021
- Legislative Related
- No
-
Medicare Compliance Review of Houston Methodist Hospital for 2012 and 2013
16-A-06-165.01We recommend that the Hospital refund to the Medicare contractor $579,799 in estimated net overpayments for claims that were incorrectly billed during the 3-year recovery period.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $579,799
- Last Update Received
- -
- Closed Date
- 04/07/2023
- Legislative Related
- No
16-A-06-165.03We recommend that the Hospital work with the Medicare contractor to return overpayments that were made outside of the 3-year recovery period, which we estimate to be as much as $619,350 for our audit period, in accordance with the 60-day repayment rule.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/07/2023
- Legislative Related
- No