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
-
First Coast Service Options, Inc., Overstated Its Medicare Segment Postretirement Benefit Assets
17-A-07-133.01We recommend that FCSO decrease its Medicare segment PRB assets by $4,997,091 as of January 1, 2013.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/03/2022
- Legislative Related
- No
-
Medicare Could Save Millions by Eliminating the Lump-Sum Purchase Option for All Power Mobility Devices
17-A-05-119.01We recommend that CMS seek legislation to eliminate the lump-sum payment option for all PMDs. If such legislation had been in place during CYs 2011 through 2014, Medicare could have saved at least an additional $10,245,539.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- 06/25/2025
- Next Update Expected
- 07/01/2025
- Legislative Related
- Yes
-
HHS Did Not Identify and Report Antideficiency Act Violations
17-A-03-118.01We recommend that the PSC work with the HHS Office of the Secretary to report Antideficiency Act obligation violations totaling $20,256,755.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Overdue
- Potential Savings
- $20,256,755
- Last Update Received
- -
- Next Update Expected
- 05/12/2022
- Legislative Related
- No
17-A-03-118.02We recommend that the PSC work with the HHS Office of the Secretary to report Antideficiency Act expenditure violations totaling $29,188,270.- Status
- Open Unimplemented
- Responsible Agency
- OS
- Response
- Overdue
- Potential Savings
- $29,188,270
- Last Update Received
- -
- Next Update Expected
- 05/12/2022
- Legislative Related
- No
17-A-03-118.03We recommend that the PSC collaborate with ASFR to identify changes to UFMS to ensure that contract expenditures for each program year are paid using the appropriate program year obligations.- Status
- Closed Implemented
- Responsible Agency
- OS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/04/2025
- Legislative Related
- No
17-A-03-118.04We recommend that the PSC use “no cost” contract extensions for severable services contracts only when they do not extend the period of performance for a program year to more than 12 months.- Status
- Closed Implemented
- Responsible Agency
- OS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/04/2025
- Legislative Related
- No
17-A-03-118.05We recommend that the PSC use product/service codes that accurately reflect the contract statement of work.- Status
- Closed Acceptable Alternative
- Responsible Agency
- OS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/04/2025
- Legislative Related
- No
-
California Incorrectly Claimed Additional Medicaid Funding Authorized Under the Recovery Act When Reclaiming Overpayments Made to Bankrupt or Out-of-Business Providers
17-A-09-102.02We recommend that the State agency ensure that it uses the FMAPs in effect when the original overpayments were made and refunded when claiming Federal reimbursement for uncollectible overpayments.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/08/2023
- Legislative Related
- No
-
New Jersey Claimed Medicaid Reimbursement for Adult Partial Hospitalization Services That Did Not Comply With Federal and State Requirements
17-A-02-100.01We recommend that the State agency refund $30,744,840 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $30,744,840
- Last Update Received
- 09/09/2025
- Next Update Expected
- 03/12/2026
- Legislative Related
- No
17-A-02-100.05We recommend that the State agency review and revise payment controls to ensure the correct rates are paid for partial hospitalization services.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/04/2024
- Legislative Related
- No
17-A-02-100.06We recommend that the State agency work with CMS to identify claims outside of our audit period that were paid at an incorrect rate or for services that were not provided by a facility licensed as a hospital.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 09/09/2025
- Next Update Expected
- 03/12/2026
- Legislative Related
- No
-
New York Improperly Claimed Federal Medicaid Reimbursement for Partial Hospitalization Services
17-A-02-078.02We recommend that the State agency work with OMH to reinforce to partial hospitalization providers the requirements for claiming Medicaid reimbursement for partial hospitalization services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/16/2022
- Legislative Related
- No
17-A-02-078.03We recommend that the State agency instruct OMH to look for the types of noncompliance we identified in this report when it performs its licensing renewal visits.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 03/16/2022
- Legislative Related
- No
-
Medicare Contractors' Payments to Providers for Hospital Outpatient Dental Services Generally Did Not Comply With Medicare Requirements
17-A-06-079.01We recommend that CMS implement national edits for hospital outpatient dental services.- Status
- Closed Acceptable Alternative
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/25/2025
- Legislative Related
- No
-
Nebraska Did Not Always Comply With Federal and State Requirements for Claims Submitted for the Nonemergency Transportation Program
17-A-07-077.01We recommend that the State agency refund to the Federal Government $1,911,138 (Federal share) in estimated overpayments. for NET claims that were in error and did not comply with Federal and State requirements.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $1,911,138
- Last Update Received
- 07/24/2017
- Next Update Expected
- 09/01/2022
- Legislative Related
- No
17-A-07-077.02We recommend that the State agency strengthen its policies and procedures to ensure that transportation services are provided only to recipients who are receiving Medicaid-covered services on the dates that they are receiving NET services; NET providers maintain records documenting that recipients are actually transported in the vehicles for all trips on the dates that NET services are rendered; NET providers maintain records to document the services provided; it does not pay NET providers or claim Federal reimbursement for non-covered transportation services; NET providers complete the required background checks on all potential drivers before permitting them to render NET services and annually thereafter, and maintain documentation of these checks; NET providers maintain records of all vehicle maintenance checks; and NET providers maintain documentation verifying that their drivers are qualified with current and valid driver's licenses.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 07/24/2017
- Next Update Expected
- 09/01/2022
- Legislative Related
- No
-
The University of California at Riverside's Pilot Payroll Certification System Did Not Provide Accountability Over Payroll Charges to Federal Awards
17-A-04-072.01We recommended that the University strengthen oversight of payroll charges to Federal awards by ensuring that, if the University returns to its prior effort-reporting system, it updates the system to adequately account for nonsponsored activities to ensure that payroll costs are properly allocated to Federal awards.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.02We recommended that the University strengthen oversight of payroll charges to Federal awards by ensuring that suitable means exist for a PI to verify that salary charges made to an award are reasonable in relation to the work performed.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.03We recommended that the University strengthen oversight of payroll charges to Federal awards by ensuring that suitable means exist to document that salary charges represent the actual work performed on a grant and not just budget estimates.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.04We recommended that the University strengthen oversight of payroll charges to Federal awards by requiring and documenting prior approval and justification for adjustments made after grant expenditures have been reported to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.05We recommended that the University strengthen oversight of payroll charges to Federal awards by requiring and documenting prior approval and justification for charging administrative and clerical salaries as direct costs.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.06We recommended that the University strengthen oversight of payroll charges to Federal awards by requiring and documenting prior approval and justification for cost transfers.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.07We recommended that the University strengthen oversight of payroll charges to Federal awards by developing payroll procedures to ensure that salaries are properly allocated and that salaries charged to all activities do not exceed 100 percent.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.08We recommended that the University strengthen oversight of payroll charges to Federal awards by following Federal requirements for supporting payroll costs claimed.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.09We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by improving restrictions for remote access.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.10We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by implementing a password setting that requires password changes periodically.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.11We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by implementing a patch management system for its desktop computers.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
17-A-04-072.12We recommended that the University strengthen its general IT controls for systems used to support the pilot PCS by implementing procedures to ensure that vendor support does not expire on the University's operating system.- Status
- Closed Implemented
- Responsible Agency
- NIH
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 12/16/2022
- Legislative Related
- No
-
Kentucky Misallocated Millions to Establishment Grants for a Health Insurance Marketplace
17-A-04-070.01We recommend that the State agency work with CMS to determine what portion of the $23.6 million was properly allocated in accordance with the relative benefits the establishment grants received from October 1, 2013, through April 15, 2014.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-04-070.02We recommend that the State agency refund $25.5 million to CMS that was misallocated to the establishment grants by not using updated, better data, or work with CMS to resolve the amount misallocated to the establishment grants, from April 16 through December 31, 2014.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $25,530,429
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-04-070.03We recommend that the State agency work with CMS to ensure that the $123.3 million that was allocated to the establishment grants on the basis of a flawed cost-allocation methodology from November 2010 through September 2013 was allocated correctly and refund any unallowable amount.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-04-070.04We recommend that the State agency work with CMS to ensure that costs claimed after our audit period were allocated correctly using updated, better data, and refund any unallowable amount.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
17-A-04-070.05We recommend that the State agency issue a written policy that explains how to develop and perform cost allocations on the basis of relative benefits received and to reassess and revise allocations when necessary.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/23/2025
- Legislative Related
- No
-
Colorado Claimed Unallowable Federal Reimbursement for Some Medicaid Physician-Administered Drugs
17-A-07-055.06We recommend that the State agency strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 05/20/2024
- Legislative Related
- No
-
Louisiana Did Not Always Comply With Federal and State Requirements for Claims Submitted for the Nonemergency Medical Transportation Program
17-A-06-053.03We recommend that the State agency, (i) strengthen its policies and procedures to ensure that providers, (ii) keep records that are necessary to document the services provided, (iii) provide transportation services only to beneficiaries receiving Medicaid-covered services, (iv) submit claims that match approved rates, and (v) do not submit claims for cancelled trips.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
17-A-06-053.04We recommend the State agency strengthen its controls over its process for reporting expenditures claimed for NEMT services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
-
Northside Medical Center Incorrectly Billed Medicare Inpatient Claims with Severe Malnutrition
17-A-03-052.01We recommend that the Hospital refund to the Medicare program $1,280,761 for the incorrectly coded claims.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $1,280,761
- Last Update Received
- -
- Closed Date
- 04/04/2022
- Legislative Related
- No
-
Delaware Did Not Bill Manufacturers for Some Rebates for Physician-Administered Drugs Dispensed to Enrollees of Medicaid Managed-Care Organizations
17-A-03-051.01We recommend that the State agency work with CMS to resolve the drug utilization without valid NDCs for which we were not able to determine an estimate by determining the correct NDCs and rebates due, billing manufacturers for the rebates, and refunding the Federal share of rebates collected.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
17-A-03-051.03We recommend that the State agency ensure that MCOs submit drug utilization data containing NDCs for all physician-administered drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
-
New Jersey Claimed Medicaid Adult Mental Health Partial Care Services That Were Not in Compliance With Federal and State Requirements
17-A-02-047.01We recommended that the State agency refund $94,830,718 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $94,830,718
- Last Update Received
- 09/09/2025
- Next Update Expected
- 03/12/2026
- Legislative Related
- No
-
Virginia Did Not Bill Manufacturers for Some Rebates for Physician-Administered Drugs Dispensed to Enrollees of Medicaid Managed-Care Organizations
17-A-03-043.03We recommend that the State agency ensure that MCOs submit drug utilization data containing NDCs for all physician-administered drugs.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 02/09/2022
- Legislative Related
- No
-
Medicare Compliance Review of North Mississippi Medical Center for 2013 and 2014
17-A-04-039.02We recommended that the Hospital 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
- $6,807
- Last Update Received
- -
- Closed Date
- 02/08/2022
- Legislative Related
- No
-
Vulnerabilities Remain Under Medicare's 2-Midnight Hospital Policy
17-E-02-008.01CMS should conduct routine analysis of hospital billing and target for review the hospitals with high or increasing numbers of short inpatient stays that are potentially inappropriate under the 2-midnight policy.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 06/17/2025
- Next Update Expected
- 07/22/2026
- Legislative Related
- No
17-E-02-008.02CMS should identify and target for review the short inpatient stays that are potentially inappropriate under the 2-midnight policy.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/22/2025
- Legislative Related
- No
17-E-02-008.03CMS should analyze the potential impacts of counting time spent as an outpatient toward the 3-night requirement for SNF services so that beneficiaries receiving similar hospital care have similar access to these services.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 02/08/2018
- Next Update Expected
- 06/16/2019
- Legislative Related
- No
17-E-02-008.04CMS should explore ways of protecting beneficiaries in outpatient stays from paying more than they would have paid as inpatients.- 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
-
Medicare Compliance Review of Abbott Northwestern Hospital for 2013 and 2014
17-A-05-038.01We recommend that the Hospital refund to the Medicare contractor $8,038,356 (of which $933,991 was overpayments identified in our sample) in estimated overpayments for incorrectly billed services.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $8,038,356
- Last Update Received
- -
- Closed Date
- 02/10/2022
- Legislative Related
- No
-
The Minnesota Marketplace Misallocated Federal Funds and Claimed Unallowable Costs
17-A-05-030.01We recommend that the Minnesota marketplace refund to CMS $346,095 that was misallocated to the establishment grants by not using the updated, better 2013 data, or work with CMS to resolve the amounts misallocated to the establishment grants.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $346,095
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No
17-A-05-030.02We recommend that the Minnesota marketplace refund to CMS $933,582 consisting of $929,582 that was paid for additional marketing work performed without a contract amendment.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $929,582
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No
17-A-05-030.03We recommend that the Minnesota marketplace refund to CMS $4,000 that was a duplicate payment.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $4,000
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No
17-A-05-030.04We recommend that the Minnesota marketplace work with CMS to ensure that costs we did not review for the audit period and costs claimed after our audit period are allocated correctly using updated cost allocation methodology.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No
17-A-05-030.05We recommend that the Minnesota marketplace implement internal controls that ensure the application of updated, better data to properly allocate costs and allocation of costs for all allocable project components.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No
17-A-05-030.06We recommend that the Minnesota marketplace strengthen senior management oversight to ensure that additional contract work is not performed before an amendment is in place.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No
17-A-05-030.07We recommend that the Minnesota marketplace implement internal controls to ensure proper prepayment review of invoices.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No
17-A-05-030.08We recommend that the Minnesota marketplace create a complete and accurate inventory record, develop procedures to ensure that it maintains complete and accurate inventory records for equipment purchased with establishment grant funds, and conduct a physical inventory at least biennially.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/21/2025
- Legislative Related
- No