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
-
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
-
Advanced Chiropractic Services Received Unallowable Medicare Payments for Chiropractic Services
15-A-07-145.03We recommend that ACS establish adequate policies and procedures to ensure that chiropractic services billed to Medicare are adequately documented in the medical records.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 10/01/2021
- Legislative Related
- No
-
New Jersey Claimed Medicaid Hospice Services That Were Not in Compliance With Federal and State Requirements
15-A-02-124.01We recommend that the State agency refund $8,405,262 to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $8,405,262
- Last Update Received
- -
- Closed Date
- 03/01/2023
- Legislative Related
- No
-
Missouri Claimed Unallowable Federal Reimbursement for Some Medicaid Physician-Administered Drugs
15-A-07-115.01We recommend that the State agency refund to the Federal Government $34,181,807 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $34,181,807
- Last Update Received
- 10/07/2025
- Next Update Expected
- 05/04/2026
- Legislative Related
- No
15-A-07-115.02We recommend that the State agency refund to the Federal Government $656,150 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $656,150
- Last Update Received
- 10/07/2025
- Next Update Expected
- 05/04/2026
- Legislative Related
- No
15-A-07-115.03We recommend that the State agency work with CMS to determine the unallowable portion of the $13,225,151 (Federal share) for other claims for outpatient physician-administered drugs that were ineligible for Federal reimbursement and refund that amount.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/07/2025
- Next Update Expected
- 05/04/2026
- Legislative Related
- No
15-A-07-115.04We recommend that the State agency work with CMS to determine and refund the unallowable Federal reimbursement for physician-administered drugs claimed without NDCs and not billed for rebates after December 31, 2011.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 10/07/2025
- Next Update Expected
- 05/04/2026
- Legislative Related
- No
-
Novitas Solutions, Inc. (Formerly Highmark Medicare Services, Inc.), Did Not Always Refer Medicare Cost Reports and Reconcile Outlier Payments
15-A-05-107.01Review the 5 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, request CMS approval to recoup $11,477,187 in funds and associated interest from health care providers, and refund that amount to the Federal Government.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $11,477,187
- Last Update Received
- -
- Closed Date
- 11/10/2021
- Legislative Related
- No
-
Maryland Misallocated Millions to Establishment Grants for a Health Insurance Marketplace
15-A-01-105.01We recommend that the State agency refund $15.9 million to CMS that was misallocated to the establishment grants by not prospectively using updated actual enrollment data.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $15,900,000
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
15-A-01-105.02We recommend that the State agency refund $12.5 million to CMS that was misallocated to the establishment grants using a methodology that included a material defect.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $12,500,000
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
15-A-01-105.03We recommend that the State agency develop a written policy that explains how to calculate cost allocations and that emphasizes the necessity to use updated and actual data.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
15-A-01-105.04We recommend that the State agency immediately amend the CAP and the APD for the period July 1 through December 31, 2014, so that allocated costs correspond to the relative benefits received.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
15-A-01-105.05We recommend that the State agency oversee operations to ensure (1) the identification and correction of enrollment projection errors, (2) the use of better or updated enrollment data, and (3) the application of these data to allocate costs.- Status
- Closed Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 07/17/2025
- Legislative Related
- No
-
National Government Services, Inc., Did Not Always Refer Medicare Cost Reports and Reconcile Outlier Payments in Jurisdiction 8
15-A-05-099.03Review the 6 cost reports that were referred to CMS and had outlier payments that qualified for reconciliation and work with CMS to reconcile the $10,855,073 in associated outlier payments due to the Federal Government, finalize these cost reports, and ensure that the providers return the funds to Medicare.- Status
- Closed Implemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $10,855,073
- Last Update Received
- -
- Closed Date
- 10/02/2021
- Legislative Related
- No
-
Medicare Could Have Saved Billions at Critical Access Hospitals If Swing-Bed Services Were Reimbursed Using the Skilled Nursing Facility Prospective Payment System Rates
15-A-05-094.01We recommend that CMS seek legislation to adjust CAH swing-bed reimbursement rates to the lower SNF PPS rates paid for similar services at alternative facilities.- Status
- Closed Superseded
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 04/16/2025
- Legislative Related
- Yes
-
New York State Improperly Claimed Medicaid Reimbursement for Continuous 24-Hour Personal Care Claims in Ulster County
15-A-02-093.01We recommend that the State agency refund $6,276,189 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $6,276,189
- Last Update Received
- 11/04/2025
- Next Update Expected
- 05/04/2026
- Legislative Related
- No
-
Not All Children in Foster Care Who Were Enrolled in Medicaid Received Required Health Screenings
15-E-07-020.01ACF should expand the scope of the Child and Family Services Reviews to determine whether children in foster care receive required health screenings according to the timeframes specified in States' plans.- Status
- Closed Implemented
- Responsible Agency
- ACF
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- -
- Closed Date
- 11/16/2023
- Legislative Related
- No
-
New York State Improperly Claimed Medicaid Reimbursement for Continuous 24-Hour Personal Care Claims
15-A-02-086.01The State agency should refund $12,063,508 to the Federal Government.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $12,063,508
- Last Update Received
- 09/12/2025
- Next Update Expected
- 03/12/2026
- Legislative Related
- No
-
Acute-Care Hospitals in Ohio Did Not Always Reconcile Invoice Records With Credit Balances and Refund the Associated Medicaid Overpayments to the State Agency
15-A-05-071.01We recommend that the State agency refund $26,426 to the Federal Government for overpayments paid to the selected hospitals.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Concur
- Potential Savings
- $26,426
- Last Update Received
- 07/31/2015
- Next Update Expected
- 07/30/2022
- Legislative Related
- No
15-A-05-071.02We recommend that the State agency enhance its efforts to recover additional overpayments estimated at $4,630,721 ($3,048,126 Federal share) from our audit period and realize future savings by requiring hospitals to reconcile invoice records with credit balances and reporting the associated Medicaid overpayments.- Status
- Open Unimplemented
- Responsible Agency
- CMS
- Response
- Non-Concur
- Potential Savings
- $3,048,126
- Last Update Received
- 08/13/2018
- Next Update Expected
- 07/30/2022
- Legislative Related
- No
-
Federal Marketplace: Inadequacies in Contract Planning and Procurement
15-E-03-014.06HHS should revise its guidance to include specific standards for conducting past performance reviews of companies under consideration during contract procurement.- Status
- Open Unimplemented
- Responsible Agency
- ASFR
- Response
- Concur
- Potential Savings
- -
- Last Update Received
- 08/26/2025
- Next Update Expected
- 09/15/2026
- Legislative Related
- No