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 November 14, 2025
1,188
Unimplemented
recommendations
3,135
Implemented and Closed
recommendations since FY 2017
Views
OIG Recommendations Grouped by Report
Showing 361–380 of 1,340 reports, containing 4,323 recommendations
Sorted by latest release date
-
Medicare Providers Did Not Always Comply With Federal Requirements When Billing for Advance Care Planning
23-A-06-017.01The 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.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $42,233,599
- Last Update Received
- -
- Closed Date
- 09/26/2023
- Legislative Related
- No
23-A-06-017.02The Centers for Medicare & Medicaid Services should instruct the MACs to recoup $33,332 for ACP services paid in error for claims in our sample.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $33,332
- Last Update Received
- -
- Closed Date
- 03/12/2024
- Legislative Related
- No
23-A-06-017.03The 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/11/2025
- Next Update Expected
- 09/13/2025
- Legislative Related
- No
23-A-06-017.04The 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.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/26/2023
- Legislative Related
- No
-
Puerto Rico MMIS and E&E Systems Security Controls Were Generally Effective, but Some Improvements Are Needed
23-A-18-016.01We 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/22/2025
- Next Update Expected
- 04/22/2026
- Legislative Related
- No
23-A-18-016.02We recommend that the Puerto Rico Department of Health assess and adjust, if necessary, at least annually, the cryptographic configurations of public servers.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/22/2025
- Next Update Expected
- 04/22/2026
- Legislative Related
- No
-
National Government Services, Inc., Accurately Calculated Hospice Cap Amounts but Did Not Collect All Cap Overpayments
23-A-06-015.01We 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.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $2,138,011
- Last Update Received
- -
- Closed Date
- 05/22/2024
- Legislative Related
- No
23-A-06-015.02We 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.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/04/2024
- Legislative Related
- No
23-A-06-015.03We 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.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/04/2024
- Legislative Related
- No
-
Medicare Advantage Compliance Audit of Specific Diagnosis Codes That BCBS of Rhode Island (Contract H4152) Submitted to CMS
23-A-01-013.01We recommend that Blue Cross & Blue Shield of Rhode Island refund to the Federal Government the $4,894,595 of estimated net overpayments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $4,894,595
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
23-A-01-013.02We 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
23-A-01-013.03We 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
-
Long-Term Trends of Psychotropic Drug Use in Nursing Homes
23-E-07-003.01CMS should evaluate the use of psychotropic drugs among nursing home residents to determine whether additional action is needed to ensure that use among residents is appropriate.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 04/08/2024
- Next Update Expected
- 04/10/2025
- Legislative Related
- No
23-E-07-003.02CMS should use data to identify nursing homes or nursing home characteristics that are associated with a higher use of psychotropic drugs and focus oversight on nursing homes in which trends may signal inappropriate use.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 04/08/2024
- Next Update Expected
- 04/10/2025
- Legislative Related
- No
23-E-07-003.03CMS should expand the required data elements on Medicare Part D claims to include a diagnosis code.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 06/04/2024
- Next Update Expected
- 07/02/2025
- Legislative Related
- No
-
Medicare Advantage Compliance Audit of Specific Diagnosis Codes That California Physicians' Service, Inc. (Contract H0504) Submitted to CMS
23-A-09-012.01We recommend that California Physicians' Service, Inc. refund to the Federal Government the $2,033,039 of estimated net overpayments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $2,033,039
- Last Update Received
- 03/21/2024
- Next Update Expected
- 03/17/2026
- Legislative Related
- No
23-A-09-012.02We recommend that California Physicians' Service, Inc. 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/21/2024
- Next Update Expected
- 03/17/2026
- Legislative Related
- No
23-A-09-012.03We recommend that California Physicians' Service, Inc. examine 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/21/2024
- Next Update Expected
- 03/17/2026
- Legislative Related
- No
-
Iowa Implemented Most of Our Prior Audit Recommendations and Generally Complied With Federal and State Requirements for Reporting and Monitoring Major Incidents
23-A-07-010.01We recommend that the Iowa Department of Human Services, Iowa Medicaid Enterprise, continue to strengthen internal controls to ensure full compliance with Federal and State requirements, to include periodically updating the list of diagnosis codes used when reviewing the Medicaid emergency room claims data to ensure that all Critical Incident Reports for major incidents were submitted as required.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/03/2023
- Legislative Related
- No
-
Three Tribes in New England and Their Health Programs Did Not Conduct Required Background Investigations on All Individuals in Contact With Indian Children
23-A-01-009.01We recommend that the Houlton Band of Maliseet Indians perform background investigations, as required by the Act, on individuals who currently have contact with Indian children and determine whether the individuals meet the required minimum character standards.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/03/2023
- Legislative Related
- No
23-A-01-009.02We recommend that the Houlton Band of Maliseet Indians develop and implement policies and procedures that ensure the Tribe conducts FBI fingerprint background investigations using FBI-approved procedures for individuals in contact with Indian children, conducts inquiries to State and Tribal law enforcement agencies based on the 5 years of residency information on each application, and assesses criminal history results to verify that applicants meet the required minimum character standards.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/03/2023
- Legislative Related
- No
23-A-01-009.03We recommend that the Houlton Band of Maliseet Indians request on employment applications information about each applicant's criminal history involving children, per the Tribe's policies and procedures related to the 1990 Crime Control Act.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/03/2023
- Legislative Related
- No
23-A-01-009.04We recommend that the Passamaquoddy Tribe at Indian Township perform background investigations, as required by the Act, on individuals who currently have contact with Indian children and determine whether the individuals meet the required minimum character standards.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/03/2023
- Legislative Related
- No
23-A-01-009.05We recommend that the Passamaquoddy Tribe at Indian Township develop and implement policies and procedures that ensure the Tribe requests information on each applicant's application about the prior 5 years of residency, conducts FBI fingerprint background investigations using FBI-approved procedures for individuals in contact with Indian children, conducts inquiries to State and Tribal law enforcement agencies based on the 5 years of residency information on each application, and assesses criminal history results to verify that applicants meet the required minimum character standards.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/03/2023
- Legislative Related
- No
23-A-01-009.06We recommend that the Narragansett Indian Tribe perform background investigations, as required by the Act, on individuals who currently have contact with Indian children and determine whether the individuals meet the required minimum character standards.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/03/2023
- Legislative Related
- No
23-A-01-009.07We recommend that the Narragansett Indian Tribe develop and implement policies and procedures that ensure the Tribe requests information on each applicant's application about the prior 5 years of residency, conducts FBI fingerprint background investigations using FBI-approved procedures for individuals in contact with Indian children, conducts inquiries to State and Tribal law enforcement agencies based on the 5 years of residency information on each application, and assesses criminal history results to verify that applicants meet the required minimum character standards.- Status
- Open Unimplemented
- Responsible Agency
- IHS
- Response
- Overdue
- Potential Savings
- -
- Last Update Received
- -
- Next Update Expected
- 05/03/2023
- Legislative Related
- No
23-A-01-009.08We recommend that the Indian Health Service continue to provide additional training and technical assistance, in collaboration with other organizations as needed, to ensure that Tribes understand and comply with the requirements to conduct background investigations and the character assessment requirements of the Act.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 01/27/2025
- Legislative Related
- No
23-A-01-009.09We recommend that the Indian Health Service continue to take the actions described in the IHS Director's Letter to Tribal Leaders to identify best practices to protect the safety and security of Indian children and collect and share this information with all participants in the IHS health system.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 01/27/2025
- Legislative Related
- No
-
During the Initial COVID-19 Response, HHS Personnel Who Interacted With Potentially Infected Passengers Had Limited Protections
23-E-04-002.01CDC should update its guidance recommending protections for personnel interacting with potentially infected passengers, particularly when data are limited.- Status
- Closed Implemented
- Responsible Agency
- CDC
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/18/2025
- Legislative Related
- No
23-E-04-002.02CDC should ensure that its PPE trainings meet OSHA standards.- Status
- Open Unimplemented
- Responsible Agency
- CDC
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 07/28/2025
- Next Update Expected
- 07/30/2026
- Legislative Related
- No
23-E-04-002.03CDC should develop a comprehensive plan for recommending travel-related containment measures that weighs the risks relative to the public health benefits.- Status
- Open Unimplemented
- Responsible Agency
- CDC
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 07/28/2025
- Next Update Expected
- 07/30/2026
- Legislative Related
- No
-
Mississippi Did Not Always Invoice Rebates to Manufacturers for Physician-Administered Drugs
23-A-07-008.01We recommend that the Mississippi Division of Medicaid refund to the Federal Government $820,732 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $820,732
- Last Update Received
- -
- Closed Date
- 04/06/2023
- Legislative Related
- No
23-A-07-008.02We recommend that the Mississippi Division of Medicaid refund to the Federal Government $395,621 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $395,621
- Last Update Received
- -
- Closed Date
- 04/06/2023
- Legislative Related
- No
23-A-07-008.03We recommend that the Mississippi Division of Medicaid work with CMS to determine the unallowable portion of $1,001,849 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement, refund that amount, and consider invoicing drug manufacturers for rebates for these drugs if CMS determines that the drug claims are allowable.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,001,849
- Last Update Received
- -
- Closed Date
- 04/06/2023
- Legislative Related
- No
23-A-07-008.04We recommend that the Mississippi Division of Medicaid strengthen internal controls for non-crossover claims to ensure that all eligible physician-administered drugs are invoiced.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/06/2023
- Legislative Related
- No
23-A-07-008.05We recommend that the Mississippi Division of Medicaid consider revising its payment methodology going forward regarding payments for crossover claims, thereby to allow collection of manufacturers' rebates for associated physician-administered drugs.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $35,611,451
- Last Update Received
- -
- Closed Date
- 04/06/2023
- Legislative Related
- No
-
CMS Can Use OIG Audit Reports To Improve Its Oversight of Hospital Compliance
23-A-04-007.01We recommend that the Centers for Medicare and Medicaid Services continue to follow up on the overpayment recovery recommendations contained in the 12 audits covered by this report.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/11/2023
- Legislative Related
- No
23-A-04-007.02We recommend that the Centers for Medicare and Medicaid Services improve tracking and responding on the status of claims identified in our reports as they proceed through the appeals process.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/30/2023
- Legislative Related
- No
23-A-04-007.03We recommend that the Centers for Medicare and Medicaid Services direct its MACs to follow up with 8 of the 12 hospitals that have not responded to the recommendation to follow the 60-day rule or have not followed up at the conclusion of the appeals process (for those that are appealing the results of their audits).- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/30/2023
- Legislative Related
- No
23-A-04-007.04We recommend that the Centers for Medicare and Medicaid Services revise its SOP to require MACs to follow up with providers at the conclusion of the appeals process and require the MACs to provide additional detail to CMS regarding specific followup actions taken.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/30/2023
- Legislative Related
- No
23-A-04-007.05We recommend that the Centers for Medicare and Medicaid Services consider the results of this audit and future hospital compliance audits in its risk assessment process.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/13/2023
- Legislative Related
- No
-
CMS Generally Ensured That Medicare Part C and Part D Sponsors Did Not Pay Ineligible Providers for Services to Medicare Beneficiaries
23-A-02-004.01We recommend that the Centers for Medicare & Medicaid Services direct Part C and Part D sponsors to recoup any recoverable payments for Medicare services made to the excluded and precluded providers identified in our audit.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/05/2023
- Legislative Related
- No
23-A-02-004.02We recommend that the Centers for Medicare & Medicaid Services direct Part C and Part D sponsors to recoup any recoverable payments for Medicare services made outside of our audit period to the excluded and precluded providers identified in our audit.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/05/2023
- Legislative Related
- No
23-A-02-004.03We recommend that the Centers for Medicare & Medicaid Services direct Part C and Part D sponsors to review their lists of contracted providers and take action to ensure that only eligible providers receive payments for Medicare services in accordance with Medicare payment rules.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/05/2023
- Legislative Related
- No
23-A-02-004.04We recommend that the Centers for Medicare & Medicaid Services determine whether any compliance actions, sanctions, or termination, are appropriate for any sponsors, if applicable.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/05/2023
- Legislative Related
- No
23-A-02-004.05We recommend that the Centers for Medicare & Medicaid Services strengthen its oversight of sponsors and provider NPIs to prevent deactivated NPIs and deceased providers from receiving payments for Medicare services.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/05/2023
- Legislative Related
- No
-
California Made Almost $16 Million in Unallowable Capitation Payments for Beneficiaries With Multiple Client Index Numbers
23-A-04-006.01We recommend that the California Department of Health Care Services refund to the Federal Government $15,722,587 in unallowable payments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $15,722,587
- Last Update Received
- -
- Closed Date
- 01/25/2023
- Legislative Related
- No
23-A-04-006.02We recommend that the California Department of Health Care Services review capitation payments that fell outside of our audit period and refund any unallowable payments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/29/2025
- Next Update Expected
- 03/30/2026
- Legislative Related
- No
23-A-04-006.03We recommend that the California Department of Health Care Services ensure that the algorithm used to create its revised Beneficiary Name and DOB Match Reports is effective at detecting individuals with multiple records.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/29/2025
- Next Update Expected
- 03/30/2026
- Legislative Related
- No
23-A-04-006.04We recommend that the California Department of Health Care Services require county staff to review training materials on the prevention of issuing multiple CINs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/29/2025
- Next Update Expected
- 03/30/2026
- Legislative Related
- No
23-A-04-006.05We recommend that the California Department of Health Care Services enhance its controls to ensure that no beneficiary is issued multiple CINs.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/29/2025
- Next Update Expected
- 03/30/2026
- Legislative Related
- No
-
Colorado Did Not Report and Refund the Correct Federal Share of Medicaid-Related Overpayments for 70 Percent of the State's Medicaid Fraud Control Unit Cases
23-A-07-005.01We recommend that the Colorado Department of Health Care Policy and Financing report and refund $3,669,738 (Federal share) in unreported MFCU-determined Medicaid overpayments that related to paid claims and court-ordered awards that have been recovered and collected.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $3,669,738
- Last Update Received
- -
- Closed Date
- 03/15/2023
- Legislative Related
- No
23-A-07-005.02We recommend that the Colorado Department of Health Care Policy and Financing determine the value of overpayments, including those related to court-ordered awards, identified after our audit period that have been recovered and collected but not reported; report them on the Form CMS-64; and refund the Federal share of the recovered overpayments and collected court-ordered awards.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/15/2023
- Legislative Related
- No
23-A-07-005.03We recommend that the Colorado Department of Health Care Policy and Financing strengthen policies and procedures to ensure that overpayments are reported correctly and in a timely manner on the Form CMS-64 in accordance with Federal requirements, to include adding instructions on how to report court-ordered awards that have been collected and the timely reporting of these overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/15/2023
- Legislative Related
- No
23-A-07-005.04We recommend that the Colorado Department of Health Care Policy and Financing strengthen policies and procedures to ensure that MFCU-determined Medicaid overpayments are reported on line 2 of the Form CMS-64.9C1 if recovered or on line 2 of the Form CMS-64.9OFWA if not recovered within timeframes specified by Federal requirements.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/15/2023
- Legislative Related
- No
-
IHS Did Not Always Provide the Necessary Resources and Assistance To Help Ensure That Tribal Programs Complied With All Requirements During Early COVID-19 Vaccination Program Administration
23-A-07-002.01We recommend that Indian Health Service ensure that Tribal programs comply with vaccine program requirements by establishing formal reconciliation processes for all IHS Areas to ensure that the data that the Tribal programs submit on doses administered are correct.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/07/2023
- Legislative Related
- No
23-A-07-002.02We recommend that Indian Health Service ensure that Tribal programs comply with vaccine program requirements by addressing data management system incompatibilities between Tribal programs and IHS.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/31/2023
- Legislative Related
- No
23-A-07-002.03We recommend that Indian Health Service work with CMS to disseminate guidance to Tribal programs on vaccine coding and billing.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/07/2023
- Legislative Related
- No
23-A-07-002.04We recommend that Indian Health Service work with CDC and the appropriate Tribal program to ensure that it returns funds to those individuals who were balance-billed inappropriately.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/07/2023
- Legislative Related
- No
23-A-07-002.05We recommend that Indian Health Service work with CDC to develop and disseminate additional guidance related to dual enrollment and together implement a formal monitoring process to assist in ensuring that Tribal programs do not enter into unallowable dual-program agreements for Federal programs.- Status
- Closed Implemented
- Responsible Agency
- IHS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/07/2023
- Legislative Related
- No
-
Home Health Agencies Used Multiple Strategies To Respond to the COVID-19 Pandemic, Although Some Challenges Persist
23-E-01-001.01CMS should evaluate how HHAs are using telehealth specifically, the types of services provided via telehealth and the characteristics of patients who benefit from these services.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/19/2024
- Next Update Expected
- 03/28/2025
- Legislative Related
- No
23-E-01-001.02CMS should to inform decision-making, evaluate how the regulatory flexibilities it has offered in response to the COVID-19 public health emergency affect the quality of home health care.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/28/2024
- Legislative Related
- No
23-E-01-001.03CMS should in collaboration with ASPR TRACIE, apply lessons learned from the COVID-19 pandemic to update and/or develop emergency preparedness trainings and materials for HHAs on responding to infectious disease outbreaks.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/19/2024
- Next Update Expected
- 03/28/2025
- Legislative Related
- No
-
Medicare Advantage Compliance Audit of Specific Diagnosis Codes That HumanaChoice (Contract R5826) Submitted to CMS
22-A-05-112.01We recommend that Humana, Inc. refund to the Federal Government the $34,414,828 of estimated overpayments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $34,414,828
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
22-A-05-112.02We recommend that Humana, Inc. 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
22-A-05-112.03We recommend that Humana, Inc. examine 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
-
UPICs Hold Promise To Enhance Program Integrity Across Medicare and Medicaid, But Challenges Remain
22-E-03-039.01CMS should implement a plan to increase UPICs' Medicaid program integrity activities, particularly related to managed care.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/30/2023
- Legislative Related
- No
22-E-03-039.02CMS should make improvements to the Unified Case Management system.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 03/24/2025
- Next Update Expected
- 03/26/2026
- Legislative Related
- No
22-E-03-039.03CMS should implement a plan to help ensure the success of the Major Case Coordination initiative for Medicaid referrals.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/19/2023
- Legislative Related
- No
22-E-03-039.04CMS should identify the reasons for the unexplained variation in program integrity activities across UPICs.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/05/2024
- Legislative Related
- No
-
Medicare Advantage Compliance Audit of Specific Diagnosis Codes That Highmark Senior Health Company (Contract H3916) Submitted to CMS
22-A-03-113.01We recommend that Highmark Senior Health Company refund to the Federal Government the $6,227,005 of estimated net overpayments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Partial Concur
- Potential Savings
- $6,227,005
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
22-A-03-113.02We recommend that Highmark identify, for the high-risk diagnoses included in the report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
22-A-03-113.03We recommend that Highmark continue its examination of its existing compliance procedures to identify areas where improvements can be made to ensure 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.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/15/2025
- Next Update Expected
- 03/15/2026
- Legislative Related
- No
-
Texas Claimed or May Have Claimed More Than $30 Million of $9.89 Billion in Federal Funds for Medicaid Uncompensated Care Payments That Did Not Meet Federal and State Requirements
22-A-06-115.01We recommend that the Texas Health and Human Services Commission work with CMS to determine whether the $33,776,649 in UC payments hospitals retained because costs were not reduced by the Medicare payments they received should be recouped and, if so, either refund the related Federal share of $19,661,532 to the Federal Government; or redistribute the recouped funds to participating hospitals that had UC costs that were not covered by the UC payments from the State.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $19,661,532
- Last Update Received
- -
- Closed Date
- 09/06/2023
- Legislative Related
- No
22-A-06-115.02We recommend that the Texas Health and Human Services Commission refund $11,058,256 to the Federal Government for the underreported UC overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $11,058,256
- Last Update Received
- -
- Closed Date
- 09/06/2023
- Legislative Related
- No
22-A-06-115.03We recommend that the Texas Health and Human Services Commission follow its CMS-approved methodology for calculating actual UC costs when reconciling initial UC payments with providers' actual UC costs, including reducing UC costs by Medicare payments providers receive.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/15/2023
- Legislative Related
- No
22-A-06-115.04We recommend that the Texas Health and Human Services Commission establish review procedures for overpayments to ensure that they are accurately entered into the State agency's accounting system and returned to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/17/2023
- Legislative Related
- No