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
-
Noridian Healthcare Solutions, LLC, Claimed Some Unallowable Medicare Pension CostsTitle
20-A-07-016.01We recommend that Noridian revise its FACPs for FYs 2011-2013 to reduce its claimed Medicare pension costs by $190799.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $190,799
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Claimed Some Unallowable Medicare Pension Costs Through Its Incurred Cost Proposals
20-A-07-017.01We recommend that Noridian work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare pension costs of $826668 for CYs 2009-2013.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $826,668
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Understated Its Medicare Segment Postretirement Benefit Assets
20-A-07-019.01We recommend that Noridian increase the Medicare segment PRB assets by $203,100 as of January 1, 2016.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $203,100
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Did Not Claim Some Allowable Medicare Postretirement Benefit Costs Through Its Incurred Cost Proposals
20-A-07-020.01We recommend that Noridian work with CMS to ensure that its final settlement of contract costs reflects an increase in Medicare PRB costs of $148,216 for CYs 2009-2013.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/07/2020
- Legislative Related
- No
-
Noridian Healthcare Solutions, LLC, Claimed Some Unallowable Medicare Postretirement Benefit Costs
20-A-07-021.01We recommend that Noridian revise its FACPs for FYs 2011-2013 to decrease its Medicare PRB costs by $103,731.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $103,731
- Last Update Received
- -
- Closed Date
- 05/07/2020
- Legislative Related
- No
-
Medicare Improperly Paid Acute-Care Hospitals $54.4 Million for Inpatient Claims Subject to the Post-Acute-Care Transfer Policy
20-A-09-014.01Direct the Medicare contractors to recover the $54,372,337 in identified overpayments in accordance with CMS's policies and procedures.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $54,372,337
- Last Update Received
- -
- Closed Date
- 09/03/2020
- Legislative Related
- No
20-A-09-014.02Identify any claims for transfers to post-acute care in which incorrect patient discharge status codes were used, and direct the Medicare contractors to recover any overpayments after our audit period.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/10/2022
- Legislative Related
- No
20-A-09-014.03Ensure that the Medicare contractors are receiving the postpayment edit's automatic notifications of improperly billed claims and are taking action by adjusting the original inpatient claims to initiate recovery of the overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/23/2021
- Legislative Related
- No
20-A-09-014.04If all of the Medicare contractors had received the postpayment edit's automatic notifications of improperly billed claims and had properly taken action since CY2013, Medicare could have saved $70,011,503.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $70,011,503
- Last Update Received
- -
- Closed Date
- 03/23/2021
- Legislative Related
- No
-
Audit of Medicare Part D Pharmacy Fees: Geisinger Health Systems, Inc.
20-A-03-013.01We recommend that Geisinger refile its DIR reports for CYs 2013, 2014, and 2015 to report the unreported point-of-sale fees ($149,199 for CY2013, $167,798 for CY 2014, and $152,853 for 2015) received from pharmacies.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $469,850
- Last Update Received
- -
- Closed Date
- 05/19/2020
- Legislative Related
- No
-
Medicare Improperly Paid Suppliers an Estimated $92.5 Million for Inhalation Drugs
20-A-09-012.01We recommend that the Centers for Medicare & Medicaid Services instruct the durable medical equipment Medicare administrative contractors to recover $36,825 in overpayments for the 39 unallowable claim lines.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $36,825
- Last Update Received
- -
- Closed Date
- 12/13/2021
- Legislative Related
- No
20-A-09-012.02We recommend that the Centers for Medicare & Medicaid Services instruct the durable medical equipment Medicare administrative contractors to notify the 22 suppliers associated with the 39 claim lines with potential overpayments of $36,825 so that those suppliers can exercise reasonable diligence to investigate and return any identified overpayments, in accordance with the 60-day rule, and identify and track any returned overpayments as having been made in accordance with this recommendation.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/13/2021
- Legislative Related
- No
20-A-09-012.03We recommend that the Centers for Medicare & Medicaid Services work with the durable medical equipment Medicare administrative contractors to do the following, which could have saved Medicare an estimated $92,471,272 for CY 2017 expand their review of suppliers' claims to include additional inhalation drugs (e.g., those with the highest reimbursement rates).- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $92,471,272
- Last Update Received
- -
- Closed Date
- 09/10/2020
- Legislative Related
- No
20-A-09-012.04We recommend that the Centers for Medicare & Medicaid Services work with the durable medical equipment Medicare administrative contractors to do the following, which could have saved Medicare an estimated $92,471,272 for CY 2017 provide additional training to suppliers on Medicare documentation requirements for inhalation drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 06/10/2020
- Legislative Related
- No
20-A-09-012.05We also recommend that the Centers for Medicare & Medicaid Services work with the durable medical equipment Medicare administrative contractors to do the following, which could have saved Medicare an estimated $92,471,272 for CY 2017 identify suppliers that consistently bill for inhalation drugs that do not comply with Medicare documentation requirements, perform reviews of those suppliers, collect the amount overpaid for unallowable claims, and educate them on Medicare requirements for inhalation drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/10/2020
- Legislative Related
- No
-
Medicare Allowable Amounts for Certain Orthotic Devices Are Not Comparable With Payments Made by Select Non-Medicare Payers
20-A-05-011.01We recommend that the Centers for Medicare & Medicaid Services review Medicare allowable amounts for 161 orthotic device HCPCS codes for which Medicare and beneficiaries paid an estimated $337,547,542 more than select non-Medicare payers and adjust the allowable amounts, as appropriate, using regulations promulgated under existing legislative authority, or if the allowable amounts cannot be adjusted using regulations promulgated under existing legislative authority, seek legislative authority to align Medicare allowable amounts for these items with payments made by select non-Medicare payers.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $337,547,542
- Last Update Received
- 09/30/2024
- Next Update Expected
- 04/01/2025
- Legislative Related
- No
20-A-05-011.02We recommend that the Centers for Medicare & Medicaid Services routinely review Medicare allowable amounts for new and preexisting orthotic devices to ensure that Medicare allowable amounts are in alignment with payments made by select non-Medicare payers or pricing trends.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/30/2025
- Next Update Expected
- 01/07/2026
- Legislative Related
- No
-
Medicare Home Health Agency Provider Compliance Review: Angels Care Home Health
20-A-07-010.01We recommend that the Agency refund to the Medicare program the portion of the $3,808,603 in estimated overpayments received during CYs 2014 and 2015 for claims incorrectly billed that are within the reopening and recovery periods.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $3,808,603
- Last Update Received
- -
- Closed Date
- 02/12/2020
- Legislative Related
- No
20-A-07-010.02We recommend that the Agency for the remaining portion of the $3,808,603 in estimated overpayments for claims that are outside the 4-year reopening period, exercise reasonable diligence to identify and return overpayments in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/28/2020
- Legislative Related
- No
20-A-07-010.03We recommend that the Agency exercise reasonable diligence to identify and return any additional similar overpayments outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/28/2020
- Legislative Related
- No
20-A-07-010.04We recommend that the Agency strengthen its controls to ensure full compliance with Medicare requirements for billing home health services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/28/2020
- Legislative Related
- No
-
Tennessee Made Unallowable Capitation Payments for Beneficiaries Assigned Multiple Medicaid Identification Numbers
20-A-04-009.01We recommend that the Division of TennCare refund to the Federal Government $378,137 (Federal share) in overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $378,137
- Last Update Received
- -
- Closed Date
- 04/02/2020
- Legislative Related
- No
20-A-04-009.02We recommend that the Division of TennCare review capitation payments that fell outside of our audit period and refund any overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $259,090
- Last Update Received
- -
- Closed Date
- 04/02/2020
- Legislative Related
- No
20-A-04-009.03We recommend that the Division of TennCare enhance or establish new controls to ensure that no beneficiary is issued multiple Medicaid ID numbers.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/02/2020
- Legislative Related
- No
-
The Centers for Medicare & Medicaid Services Could Improve Its Processes for Evaluating and Reporting Payment Recovery Savings Associated With the Fraud Prevention System
20-A-01-007.01We recommend that CMS continue to work with the Contractors and the MACs to develop strategies that improve timely coordination to give the MACs a better opportunity to recover overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/11/2020
- Legislative Related
- No
20-A-01-007.02We recommend that CMS establish a uniform methodology for the Contractors to use when reporting estimates for the value of law enforcement referrals.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/11/2020
- Legislative Related
- No
20-A-01-007.03We recommend that CMS update the FPS's law enforcement referral adjustment factor.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 08/11/2020
- Legislative Related
- No
-
Rhode Island Hospital Submitted Some Inaccurate Wage Data
20-A-01-005.01We recommend that the Rhode Island Hospital ensure that all personnel involved in Medicare wage-data reporting are fully trained in compliance with the requirements in the Manual.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/04/2020
- Legislative Related
- No
20-A-01-005.02We recommend that the Rhode Island Hospital strengthen review and reconciliation procedures to ensure that the Medicare wage data it reports to CMS in the future are accurate, allowable, supportable, and in compliance with Medicare requirements.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/04/2020
- Legislative Related
- No
-
Texas Did Not Ensure That Its Managed-Care Organizations Complied With Requirements Prohibiting Medicaid Payments for Services Related to Provider-Preventable Conditions
20-A-06-004.01We recommend that the State agency work with the five MCOs to determine the portion of the $16,734,145 that was unallowable for claims containing PPCs and its impact on current- and future-year capitation payment rates.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/30/2021
- Legislative Related
- No
20-A-06-004.02We recommend that the State agency require all its MCOs to implement policies and procedures to prohibit payments for inpatient hospital services related to treating PPCs for all provider payment methodologies.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/30/2021
- Legislative Related
- No
20-A-06-004.03We recommend that the State agency require all its MCOs to review all claims for inpatient hospital services that were paid after our audit period to determine whether any payments for services related to treating PPCs were unallowable and adjust future capitation payment rates for any unallowable payments identified.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/30/2021
- Legislative Related
- No
20-A-06-004.04We recommend that the State agency strengthen its monitoring of all its MCOs to ensure the MCOs comply with Federal and State requirements and its managed-care contracts relating to the nonpayment of PPCs.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/30/2021
- Legislative Related
- No
20-A-06-004.05We recommend that the State agency ensure all MCOs implement edits to appropriately reduce or deny claims for other PPCs.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/30/2021
- Legislative Related
- No
20-A-06-004.06We recommend that the State agency consider enforcing the provision in its contracts that allows liquidated damages to be imposed on the five MCOs due to their failure to process claims in accordance with Federal laws and regulations.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/30/2021
- Legislative Related
- No
20-A-06-004.07We recommend that the State agency include specific measures in its contracts that would allow the State agency to recoup funds from all MCOs when contract provisions and Federal and State requirements are not met—a measure that, if incorporated, could result in cost savings for Medicaid.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/30/2021
- Legislative Related
- No
-
New York State Claimed Federal Reimbursement for Unallowable Childcare Subsidies Paid to New York City
20-A-02-002.01We recommend that the New York State Office of Children and Family Services refund $24,662,410 in unallowable childcare subsidies claimed for Federal reimbursement.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- $24,662,410
- Last Update Received
- -
- Closed Date
- 09/21/2020
- Legislative Related
- No
20-A-02-002.02We recommend that the New York State Office of Children and Family Services ensure that New York City's recently implemented CCDF program controls are properly functioning.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 09/21/2020
- Legislative Related
- No
-
The Minnesota State Medicaid Agency Made Capitation Payments to Managed Care Organizations After Beneficiaries' Deaths
20-A-05-001.01We recommend that the Minnesota Department of Human Services refund $3,243,531 to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $3,243,531
- Last Update Received
- -
- Closed Date
- 01/26/2022
- Legislative Related
- No
20-A-05-001.02We recommend that the Minnesota Department of Human Services identify and recover unallowable payments made to MCOs during our audit period on behalf of the deceased beneficiaries, which we estimated to be at least $3,685,087.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/27/2022
- Legislative Related
- No
20-A-05-001.03We recommend that the Minnesota Department of Human Services identify capitation payments made on behalf of deceased beneficiaries before and after our audit period and repay the Federal share of amounts recovered.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/04/2021
- Legislative Related
- No
20-A-05-001.04We recommend that the Minnesota Department of Human Services ensure that State agency staff are properly trained to process dates of death and eligibility termination in accordance with State agency internal policies.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/15/2020
- Legislative Related
- No
20-A-05-001.05We recommend that the Minnesota Department of Human Services utilize additional sources to identify dates of death to help reduce unallowable payments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/05/2022
- Legislative Related
- No
-
Wisconsin Physicians Service Needs Enhanced Guidance and Provider Education Related to Phlebotomy Travel Allowances
19-A-06-163.01We recommend that Wisconsin Physicians Service work with the Centers for Medicare and Medicaid Services to clarify guidance to providers, which could have resulted in savings totaling an estimated $353,755 during our audit period.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $353,755
- Last Update Received
- -
- Closed Date
- 02/13/2020
- Legislative Related
- No
19-A-06-163.02We recommend that Wisconsin Physicians Service educate providers on how to correctly calculate the prorated mileage for phlebotomy travel allowance payments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/13/2020
- Legislative Related
- No
19-A-06-163.03We recommend that Wisconsin Physicians Service educate providers on their responsibility to bring any previously paid claims to their Medicare administrative contractor's attention if they were paid using the wrong rate.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/13/2020
- Legislative Related
- No
19-A-06-163.04We recommend that Wisconsin Physicians Service educate providers on their responsibility to maintain adequate documentation to support payment for phlebotomy travel allowance payments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/13/2020
- Legislative Related
- No
-
California Needs To Improve Oversight of Community-Based Adult Services Providers' Compliance With Health and Safety and Administrative Requirements
19-A-09-164.01We recommend that the California Department of Health Care Services ensure that the 24 providers we reviewed correct the 290 instances of noncompliance identified in this report.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/13/2020
- Legislative Related
- No
19-A-09-164.02We recommend that the California Department of Health Care Services work with the other administering departments to improve the oversight of providers to ensure that relicensing surveys are conducted within the required 2-year timeframe and recertification inspections evaluate all applicable compliance areas.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/13/2020
- Legislative Related
- No
-
The Next Door Foundation Claimed Unallowable Indirect Costs and Did Not Document the Funding Source of Program Expenditures in Accordance With Federal Requirements
19-A-05-162.01We recommend that the Next Door Foundation, Inc. refund $142,104 in unallowable indirect costs and work with its HHS funding agencies to ensure proper claiming of indirect costs.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- $142,104
- Last Update Received
- -
- Closed Date
- 03/17/2022
- Legislative Related
- No
19-A-05-162.02We recommend that the Next Door Foundation, Inc. ensure that contractual agreements are signed and in place before services are provided.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/17/2022
- Legislative Related
- No
19-A-05-162.03We recommend that the Next Door Foundation, Inc. ensure that cost transfers meet applicable criteria and are fully documented.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/17/2022
- Legislative Related
- No
19-A-05-162.04We recommend that the Next Door Foundation, Inc. ensure that the financial management system accurately matches expenditures with the source of funds.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/17/2022
- Legislative Related
- No
-
National Government Services, Inc., Claimed Some Unallowable Medicare Pension Costs Through Its Incurred Cost Proposals
19-A-07-157.01We recommend that NGS work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare pension costs of $1,780,718 for CYs 2007-2014.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,780,718
- Last Update Received
- -
- Closed Date
- 09/09/2020
- Legislative Related
- No