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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

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OIG's Top Unimplemented Recommendations

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Comprising monetary, programmatic, legislative, and procedural recommendations related to HHS Operating Divisions, full implementation of these recommendations could produce substantial savings for the Federal Government and taxpayers and improve the operation of HHS programs.
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Showing 1–20 of 22 recommendations Sorted by oldest release date
  • Centers for Medicare and Medicaid Services
    PROCESS
    CHANGE

    The Centers for Medicare & Medicaid Services Had Not Recovered More Than a Billion Dollars in Medicaid Overpayments Identified by OIG Audits
    19-A-05-037.03
    We recommend that CMS develop policies and procedures to improve the timeliness of recovering overpayments by setting guidelines for the amount of time CMS has to discuss with State officials regarding the audit findings; obtain documentation to substantiate the State's position; and issue the disallowance letter to the State.
    PROCESS
    CHANGE
    Implementation requires the responsible agency to change a program’s system or procedure.

    Status
    Open Unimplemented
    Issued to CMS
    12/07/2018
    Audit Report
    A-05-17-00013
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    Key Medicare Tools To Safeguard Against Pharmacy Fraud and Inappropriate Billing Do Not Apply to Part D
    20-E-02-010.01
    CMS should allow revocation of Medicare enrollment for inappropriate billing of Part D.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    03/05/2020
    Evaluation Report
    OEI-02-15-00440
  • Office of the Secretary
    PROCESS
    CHANGE

    HHS Office of the Secretary Should Improve Preventative and Detective Controls to More Effectively Mitigate the Risk of Compromise
    20-A-18-100.02
    Restrict users' ability (via permissions or application whitelisting) to install and run unauthorized software applications or commands on OS systems. Do not add users to the local administrator's group unless their job responsibilities require such elevated access.
    PROCESS
    CHANGE
    Implementation requires the responsible agency to change a program’s system or procedure.

    Status
    Open Unimplemented
    Issued to OS
    04/21/2020
    Audit Report
    A-18-18-08600
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    Office of Inspector General Penetration Test of the Centers for Medicare & Medicaid Services Affordable Care Act Information Systems
    20-A-18-101.09
    Implement controls to identify and authenticate devices connecting to the CMS network.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    04/28/2020
    Audit Report
    A-18-18-08400
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    CMS's Encounter Data Lack Essential Information That Medicare Advantage Organizations Have the Ability to Collect
    20-E-03-037.01
    CMS should require MAOs to submit the ordering provider NPI on encounter records for DMEPOS and for laboratory, imaging, and home health services.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    08/24/2020
    Evaluation Report
    OEI-03-19-00430
  • Centers for Medicare and Medicaid Services
    $993.1M
    Potential Savings

    Medicare Could Have Saved Approximately $993 Million in 2017 and 2018 if It Had Implemented an Inpatient Rehabilitation Facility Transfer Payment Policy for Early Discharges to Home Health Agencies
    22-A-01-020.01
    We recommend that the Centers for Medicare & Medicaid Services expand the IRF transfer payment policy to apply to early discharges to home health care. If this expanded policy had been in place, Medicare could have saved $993,134,059 in 2017 and 2018.
    $993.1M
    Potential Savings

    Status
    Open Unimplemented
    Issued to CMS
    12/07/2021
    Audit Report
    A-01-20-00501
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    Adverse Events in Hospitals: A Quarter of Medicare Patients Experienced Harm in October 2018
    22-E-06-017.01
    CMS should update and broaden its lists of hospital-acquired conditions to capture common, preventable, and high-cost harm events.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    05/05/2022
    Evaluation Report
    OEI-06-18-00400
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    Long-Term Trends of Psychotropic Drug Use in Nursing Homes
    23-E-07-003.03
    CMS should expand the required data elements on Medicare Part D claims to include a diagnosis code.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    11/10/2022
    Evaluation Report
    OEI-07-20-00500
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    More Than a Thousand Nursing Homes Reached Infection Rates of 75 Percent or More in the First Year of the COVID-19 Pandemic; Better Protections Are Needed for Future Emergencies
    23-E-02-009.02
    CMS should improve how surveys identify infection control risks to nursing home residents and strengthen guidance on assessing the scope and severity of those risks.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    01/12/2023
    Evaluation Report
    OEI-02-20-00491
  • Centers for Medicare and Medicaid Services
    $128.0M
    Potential Savings

    Medicare Could Have Saved Up To $128 Million Over 5 Years if CMS Had Implemented Controls To Address Duplicate Payments for Services Provided to Individuals With Medicare and Veterans Health Administration Benefits
    23-A-09-066.03
    We recommend that the Centers for Medicare & Medicaid Services establish an internal process (such as system edits) to address duplicate payments made by Medicare for medical services authorized and paid for by VHA, which could have saved Medicare up to $128 million during our audit period.
    $128.0M
    Potential Savings

    Status
    Open Unimplemented
    Issued to CMS
    04/24/2023
    Audit Report
    A-09-22-03004
  • Centers for Medicare and Medicaid Services
    REGULATORY
    CHANGE

    Medicare Paid Millions More for Physician Services at Higher Nonfacility Rates Rather Than at Lower Facility Rates While Enrollees Were Inpatients of Facilities
    23-A-04-080.04
    We recommend that the Centers for Medicare & Medicaid Services take the necessary steps, including seeking legislative authority, if necessary, to revise its regulations to ensure that Medicare pays the facility rate for physician services furnished while enrollees are Part A SNF or hospital inpatients irrespective of where the services are actually furnished or otherwise ensure that Medicare does not pay twice for any of the practice expenses incurred for physician services furnished while enrollees were Part A SNF or hospital inpatients, which could have resulted in the Medicare program paying up to $22,142,489 less and enrollees paying up to $5,609,125 less in cost-sharing during our 2-year audit period.
    REGULATORY
    CHANGE
    Implementation requires the responsible agency to promulgate or change a regulation that implements a statute or law.

    Status
    Open Unimplemented
    Issued to CMS
    05/30/2023
    Audit Report
    A-04-21-04084
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    High Rates of Prior Authorization Denials by Some Plans and Limited State Oversight Raise Concerns About Access to Care in Medicaid Managed Care
    23-E-09-029.04
    CMS should require States to implement automatic external medical reviews of upheld MCO prior authorization denials.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    07/17/2023
    Evaluation Report
    OEI-09-19-00350
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    Biosimilars Have Lowered Costs for Medicare Part B and Enrollees, but Opportunities for Substantial Spending Reductions Still Exist
    23-E-05-042.01
    CMS should pursue one or more payment changes that could further realize savings from biosimilars for Part B and enrollees.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    09/26/2023
    Evaluation Report
    OEI-05-22-00140
  • Centers for Medicare and Medicaid Services
    $694.0M
    Potential Savings

    Medicare Could Save Millions if It Implements an Expanded Hospital Transfer Payment Policy for Discharges to Postacute Care
    24-A-01-002.01
    We recommend that CMS conduct an analysis of its hospital transfer payment policy for discharges to PAC and expand the policy as necessary.
    $694.0M
    Potential Savings

    Status
    Open Unimplemented
    Issued to CMS
    10/06/2023
    Audit Report
    A-01-21-00504
  • Centers for Medicare and Medicaid Services
    PROCESS
    CHANGE

    CMS Did Not Ensure That Selected States Complied With Medicaid Managed Care Mental Health and Substance Use Disorder Parity Requirements
    24-A-02-050.03
    We recommend that the Centers for Medicare & Medicaid Services improve its oversight of States' compliance with MH/SUD parity requirements, including following up with any States that have identified any noncompliance with parity requirements to verify that the States have taken actions to address the noncompliance.
    PROCESS
    CHANGE
    Implementation requires the responsible agency to change a program’s system or procedure.

    This recommendation was implemented on September 16, 2025 after the OIG's list of Top Unimplemented Recommendations was published.
    Status
    Closed Implemented
    Issued to CMS
    03/25/2024
    Audit Report
    A-02-22-01016
  • Food and Drug Administration
    PROCESS
    CHANGE

    The Food and Drug Administration’s Inspection and Recall Process Should Be Improved To Ensure the Safety of the Infant Formula Supply
    24-A-01-080.07
    We recommend that the Food and Drug Administration design and implement policies and procedures specific to the use of its FDA-required infant formula recall authority.
    PROCESS
    CHANGE
    Implementation requires the responsible agency to change a program’s system or procedure.

    Status
    Open Unimplemented
    Issued to FDA
    06/10/2024
    Audit Report
    A-01-22-01502
  • Administration for Children and Families
    PROGRAM
    CHANGE

    Many States Lack Information To Monitor Maltreatment in Residential Facilities for Children in Foster Care
    24-E-07-018.02
    ACF should help States to improve their abilities to monitor patterns of maltreatment and performance across chains of residential facilities operating in multiple States.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to ACF
    06/21/2024
    Evaluation Report
    OEI-07-22-00530
  • National Institutes of Health
    PROCESS
    CHANGE

    The National Institutes of Health Has Made Progress But Could Further Improve Its Closeout Process for Grants and Similar Awards
    24-A-04-084.02
    We recommend that the National Institutes of Health facilitate timely unilateral closeout within 1 year of the PPE date by implementing a policy that requires the unilateral closeout process be completed early enough to allow for final closeout within 1 year of the PPE date; and providing additional training to staff involved in the closeout process to increase staff awareness (i.e., sending monitoring reports to ICs for awards eligible for unilateral closeout).
    PROCESS
    CHANGE
    Implementation requires the responsible agency to change a program’s system or procedure.

    Status
    Open Unimplemented
    Issued to NIH
    06/25/2024
    Audit Report
    A-04-23-08097
  • Centers for Medicare and Medicaid Services
    $953.4K
    Potential Savings

    Medicare Part D Paid Millions for Drugs for Which Payment Was Available Under the Medicare Part A Skilled Nursing Facility Benefit
    25-A-09-003.01
    We recommend that the Centers for Medicare & Medicaid Services work with its plan sponsors to adjust or delete PDEs, as necessary, and determine the impact to the Federal Government related to the Medicare Part D total costs of $953,370 for drugs associated with our sample items for which payment was available under the Medicare Part A SNF benefit, which included $541,652 for drugs that were administered during Part D enrollees' Part A SNF stays.
    $953.4K
    Potential Savings

    Status
    Open Unimplemented
    Issued to CMS
    10/18/2024
    Audit Report
    A-09-21-03008
  • Centers for Medicare and Medicaid Services
    $4.2B
    Potential Savings

    Medicare Advantage: Questionable Use of Health Risk Assessments Continues To Drive Up Payments to Plans by Billions
    25-E-03-003.01
    CMS should impose additional restrictions on the use of diagnoses reported only on in-home HRAs or chart reviews that are linked to in-home HRAs for risk-adjusted payments.
    $4.2B
    Potential Savings

    Status
    Open Unimplemented
    Issued to CMS
    10/21/2024
    Evaluation Report
    OEI-03-23-00380