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 February 17, 2026
1,171
Unimplemented
recommendations
3,212
Implemented and Closed
recommendations since FY 2017
Views
OIG Recommendations Grouped by Report
-
Opportunities for Program Improvements Related to States' Withdrawals of Federal Medicaid Funds
16-A-06-104.01We recommend that CMS issue guidance that clarifies existing requirements and provides further interpretation of the "as needed" language in 42 CFR § 430.30(d)(3) as it relates to the withdrawal of Medicaid funds.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/05/2024
- Legislative Related
- No
16-A-06-104.02We recommend that CMS publish regulations that are consistent with the Treasury provisions in 31 CFR part 205 and educate States.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/20/2024
- Legislative Related
- No
16-A-06-104.03We recommend that CMS publish and enforce formal guidance based on the November 8, 2011, email, so that States are aware of the appropriate PMS account from which to withdraw or return fund.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/05/2024
- Legislative Related
- No
16-A-06-104.04We recommend that CMS require States to reconcile total Federal Medicaid funds withdrawn with the Federal share of net expenditures and issue appropriate reconciliation guidelines.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/05/2024
- Legislative Related
- No
-
California Improperly Claimed Enhanced Federal Reimbursement for Selected Claim Lines for Medicaid Family Planning Drugs and Supplies in Los Angeles and Orange Counties
16-A-09-098.04We recommend that the State agency ensure that providers comply with State agency policies and procedures requiring them to verify the accuracy of submitted claims for family planning drugs and supplies.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
-
Missouri Claimed Unallowable Medicaid Payments for Individualized Supported Living Habilitation Services
16-A-07-093.01We recommend that the State agency refund $1,455,378 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,455,378
- Last Update Received
- 10/02/2025
- Next Update Expected
- 04/02/2026
- Legislative Related
- No
-
Nevada Misallocated Costs for Establishing a Health Insurance Marketplace to Its Establishment Grants
16-A-09-079.01We recommend that the Nevada marketplace refund to CMS $893,464, consisting of $26,685 that was misallocated to the establishment grants by not using updated, better data and $866,779 that was misallocated to the establishment grants for BOS components 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
- $893,464
- Last Update Received
- -
- Closed Date
- 01/10/2025
- Legislative Related
- No
16-A-09-079.02We recommend that the Nevada marketplace work with CMS to ensure that costs claimed after our audit period are allocated correctly, using an updated cost allocation methodology.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 01/10/2025
- Legislative Related
- No
16-A-09-079.03We recommend that the Nevada marketplace develop a written policy that explains how to perform cost allocations and emphasizes the necessity to use updated, better data when available.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 01/10/2025
- Legislative Related
- No
16-A-09-079.04We recommend that the Nevada marketplace strengthen staff oversight to ensure (1) application of updated, better data to properly allocate costs and (2) allocation of costs for all allocable project components.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 01/10/2025
- Legislative Related
- No
-
Promise Hospital of Ascension Incorrectly Billed Medicare Inpatient Claims With Kwashiorkor
16-A-03-073.01We recommend that Promise Healthcare refund to the Medicare program $465,079 for the incorrectly coded claims.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $465,079
- Last Update Received
- -
- Closed Date
- 12/23/2021
- Legislative Related
- No
-
Most Children With Medicaid in Four States Are Not Receiving Required Dental Services
16-E-02-008.02CMS should develop benchmarks for dental services and require States to create mandatory action plans to meet them.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/05/2024
- Legislative Related
- No
16-E-02-008.04CMS should work with States to analyze the effects of Medicaid payments on access to dental providers.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/09/2025
- Legislative Related
- No
16-E-02-008.06CMS should work with States to track children's utilization of required dental services.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/05/2024
- Legislative Related
- No
-
Not All of the Colorado Marketplace's Internal Controls Were Effective in Ensuring That Individuals Were Enrolled in Qualified Health Plans According to Federal Requirements
16-A-07-050.01We recommend that the Colorado marketplace improve the design of its enrollment system to verify the eligibility of applicants who opted not to participate in the insurance affordability programs and who enrolled in a QHP.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/03/2022
- Legislative Related
- No
16-A-07-050.02We recommend that the Colorado marketplace improve the design of its enrollment system to verify eligibility by obtaining OPM or non-ESI data through the Data Hub.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/03/2022
- Legislative Related
- No
-
New York State Improperly Claimed Medicaid Reimbursement for Some Adult Day Health Care Services
16-A-02-049.01We recommend that the State agency refund $70,486,492 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $70,486,492
- Last Update Received
- 09/11/2025
- Next Update Expected
- 03/11/2026
- Legislative Related
- No
-
Hoveround Corporation Claimed Millions in Federal Reimbursement for Power Mobility Devices That Did Not Meet Medicare Requirements
16-A-05-035.01We recommend that Hoveround refund $27,027,579 to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $27,027,579
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
-
Wisconsin Inappropriately Withdrew Federal Medicaid Funds for Fiscal Years 2010 Through 2012
16-A-05-005.01We recommend that the State agency refund $89,624,201 to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $89,624,201
- Last Update Received
- -
- Closed Date
- 03/14/2024
- Legislative Related
- No
-
Total Sleep Management, Inc., Billed Medicare for Unallowable Sleep Study Services
16-A-04-004.01We recommend that Total Sleep refund to the Medicare program $423,008 in estimated overpayments for claims that it incorrectly billed that are within the 3-year recovery period.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $423,008
- Last Update Received
- -
- Closed Date
- 10/25/2021
- Legislative Related
- No
-
CMS Should Use Targeted Tactics to Curb Questionable and Inappropriate Payments for Chiropractic Services
15-E-01-058.01CMS should establish a more reliable control for identifying active treatment.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/19/2024
- Legislative Related
- No
-
The Medicare Payment System for Skilled Nursing Facilities Needs To Be Reevaluated
15-E-02-057.01CMS should evaluate the extent to which Medicare payment rates for therapy should be reduced.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/23/2025
- Next Update Expected
- 07/01/2025
- Legislative Related
- Yes
15-E-02-057.03CMS should adjust Medicare payments to eliminate the effect of case mix-creep.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/24/2024
- Next Update Expected
- 06/26/2025
- Legislative Related
- No
-
Inappropriate Payments and Questionable Billing for Medicare Part B Ambulance Transports
15-E-09-056.02CMS should require ambulance suppliers to include the National Provider Identifier of the certifying physician on transport claims that require certification.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/24/2025
- Legislative Related
- No
-
National Government Services, Inc., Did Not Always Refer Medicare Cost Reports and Reconcile Outlier Payments
15-A-05-236.01Review the 10 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, and request CMS approval to recoup $19,689,662 in funds and associated interest from health care providers (8 cost reports), and refund that amount to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $19,689,662
- Last Update Received
- -
- Closed Date
- 03/04/2025
- Legislative Related
- No
15-A-05-236.05Review the 24 cost reports that were referred to CMS and had outlier payments that qualified for reconciliation and work with CMS to reconcile the $102,498,576 in associated outlier payments due to the Federal Government (22 cost reports), finalize these cost reports, and ensure that the providers return the funds to Medicare.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $102,498,576
- Last Update Received
- -
- Closed Date
- 03/04/2025
- Legislative Related
- No
15-A-05-236.07Work with CMS to resolve the $9,778 in outlier payments associated with one claim that we could not recalculate.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $9,778
- Last Update Received
- -
- Closed Date
- 03/04/2025
- Legislative Related
- No
-
Some of New Jersey's Claims for Medicaid Personal Care Services Did Not Comply With Federal and State Requirements
15-A-02-210.01We recommend that the State agency refund $32,236,308 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $32,236,308
- Last Update Received
- 09/09/2025
- Next Update Expected
- 03/10/2026
- Legislative Related
- No
-
Providers Did Not Always Reconcile Patient Records With Credit Balances and Report and Return the Associated Medicaid Overpayments to State Agencies
15-A-04-212.01We recommended that CMS issue Medicaid regulations to clarify the requirements of the Affordable Care Act that parallel its proposed Medicare rules and require that States ensure that providers exercise reasonable diligence to identify, report, and return overpayments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/18/2025
- Next Update Expected
- 09/18/2025
- Legislative Related
- No
-
Missouri Claimed Unallowable and Unsupported Medicaid Payments for Group Home Habilitation Services
15-A-07-198.01We recommend that the State agency refund $3,034,157 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $3,034,157
- Last Update Received
- 10/08/2025
- Next Update Expected
- 04/08/2026
- Legislative Related
- No
-
Arkansas Made Incorrect Medicaid Electronic Health Record Incentive Payments to Hospitals
15-A-06-168.01Refund to the Federal government $79,428 in net overpayments made to the 13 hospitals.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $79,428
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
15-A-06-168.02Adjust the 13 hospitals' remaining incentive payments to account for the incorrect calculations (which will result in future cost savings of $134,295).- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $134,295
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
15-A-06-168.04Review supporting documentation for the numbers provided in the cost reports and ensure that the correct cost report periods are used.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
15-A-06-168.05Provide guidance to the hospitals that states that inpatient nonacute-care services and unpaid Medicaid services should be excluded from bed days and discharges lines of the incentive payment calculation, neonatal intensive care units bed days and discharges should be included, and bad debts, courtesy discounts and any other unallowable charges should be excluded from charity care charges.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/31/2021
- Legislative Related
- No
-
Illinois Improperly Claimed Medicaid Reimbursement for Optical Services and Supplies
15-A-05-155.01We recommend that the State agency refund $488,456 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $488,456
- Last Update Received
- 10/06/2025
- Next Update Expected
- 04/06/2026
- Legislative Related
- No