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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—a subset that we think, if implemented, would have the most impact (learn more). Notable differences from our previous Top Unimplemented Recommendations report include:

  • The list is comprised of individual recommendations from OIG reports, not rolled up by topic.
  • No arbitrary cap is imposed on the number of recommendations included.
  • Status updates as recommendations are implemented.

Summary of All Recommendations

Updated Monthly · Last updated on November 15, 2024

1,310

Unimplemented
recommendations

$270.4B

Potential savingsfrom unimplemented recommendations

2,698

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 33 recommendations Sorted by oldest release date
  • Centers for Medicare and Medicaid Services
    LEGISLATIVE
    CHANGE

    Least Costly Alternative Policies: Impact on Prostate Cancer Drugs Covered Under Medicare Part B
    13-E-12-012.01
    CMS should consider seeking legislative authority to implement Least Costly Alternative (LCA) policies for Part B drugs under appropriate circumstances.
    LEGISLATIVE
    CHANGE
    Implementation requires Congress to change or enact a law.

    Status
    Open Unimplemented
    Issued to CMS
    11/21/2012
    Evaluation Report
    OEI-12-12-00210
  • Centers for Medicare and Medicaid Services
    LEGISLATIVE
    CHANGE

    Medicare and Beneficiaries Could Save Billions If CMS Reduces Hospital Outpatient Department Payment Rates for Ambulatory Surgical Center-Approved Procedures to Ambulatory Surgical Center Payment Rates
    14-A-05-157.01
    Seek legislation that would exempt the reduced expenditures as a result of lower OPPS payment rates from budget neutrality adjustments for ASC-approved procedures.
    LEGISLATIVE
    CHANGE
    Implementation requires Congress to change or enact a law.

    Status
    Open Unimplemented
    Issued to CMS
    04/16/2014
    Audit Report
    A-05-12-00020
  • Centers for Medicare and Medicaid Services
    LEGISLATIVE
    CHANGE

    Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity: An OIG Portfolio
    18-E-02-030.15
    CMS should modify the payments for hospice care in nursing facilities.
    LEGISLATIVE
    CHANGE
    Implementation requires Congress to change or enact a law.

    Status
    Open Unimplemented
    Issued to CMS
    07/30/2018
    Evaluation Report
    OEI-02-16-00570
  • 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
    $160.8M
    Potential Savings

    Medicare Part D Is Still Paying Millions for Drugs Already Paid for Under the Part A Hospice Benefit
    19-A-06-139.01
    CMS must do more to avoid paying twice for the same drugs. As we have previously recommended, CMS should work directly with hospices to ensure that they are providing drugs covered under the hospice benefit. In addition, we recommend that CMS should develop and execute a strategy to ensure that Part D does not pay for drugs that should be covered by the Part A hospice benefit, which would save at least an estimated $160.8 million a year in Part D total cost, with potentially much higher annual savings associated with the drugs that hospices said they were not responsible for providing. This should include working with Part D sponsors and seeking whatever authorities are necessary to develop proper controls.
    $160.8M
    Potential Savings

    Status
    Open Unimplemented
    Issued to CMS
    08/22/2019
    Audit Report
    A-06-17-08004
  • Centers for Medicare and Medicaid Services
    $337.5M
    Potential Savings

    Medicare Allowable Amounts for Certain Orthotic Devices Are Not Comparable With Payments Made by Select Non-Medicare Payers
    20-A-05-011.01
    We 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.
    $337.5M
    Potential Savings

    Status
    Open Unimplemented
    Issued to CMS
    10/30/2019
    Audit Report
    A-05-17-00033
  • Centers for Medicare and Medicaid Services
    PROGRAM
    CHANGE

    Billions in Estimated Medicare Advantage Payments From Chart Reviews Raise Concerns
    20-E-03-003.03
    CMS should reassess the risks and benefits of allowing chart reviews that are not linked to service records to be used as sources of diagnoses for risk adjustment.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    12/10/2019
    Evaluation Report
    OEI-03-17-00470
  • 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
    PROGRAM
    CHANGE

    Billions in Estimated Medicare Advantage Payments From Diagnoses Reported Only on Health Risk Assessments Raise Concerns
    20-E-03-039.04
    CMS should reassess the risks and benefits of allowing in-home HRAs to be used as sources of diagnoses for risk adjustment and reconsider excluding such diagnoses from risk adjustment.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to CMS
    09/08/2020
    Evaluation Report
    OEI-03-17-00471
  • Centers for Medicare and Medicaid Services
    REGULATORY
    CHANGE

    CMS Should Strengthen Its Prescription Drug Event Guidance To Clarify Reporting of Sponsor Margin for Medicare Part D Bids
    22-A-03-017.01
    We recommend that the Centers for Medicare & Medicaid Services update its PDE guidance to address margin under sponsor delivery models in which a sponsor owns a pharmacy.
    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
    11/22/2021
    Audit Report
    A-03-17-00001
  • 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
    REGULATORY
    CHANGE

    Medicare and Beneficiaries Paid Substantially More to Provider-Based Facilities in Eight Selected States in Calendar Years 2010 Through 2017 Than They Paid to Freestanding Facilities in the Same States for the Same Type of Services
    22-A-07-067.01
    We recommend that CMS pursue legislative or regulatory changes to lower costs for both the Medicare program and beneficiaries, by equalizing payments as appropriate between provider based facilities and freestanding facilities for E&M services.
    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
    06/10/2022
    Audit Report
    A-07-18-02815
  • Food and Drug Administration
    PROGRAM
    CHANGE

    FDA Repeatedly Adapted Emergency Use Authorization Policies To Address the Need for COVID-19 Testing
    22-E-01-034.01
    FDA should assess and, as appropriate, revise FDA guidance for test Emergency Use Authorization (EUA) submissions.
    PROGRAM
    CHANGE
    Implementation requires the responsible agency to change a program’s policies, activities, requirements, etc.

    Status
    Open Unimplemented
    Issued to FDA
    09/16/2022
    Evaluation Report
    OEI-01-20-00380
  • Centers for Medicare and Medicaid Services
    PROCESS
    CHANGE

    Nearly All States Made Capitation Payments for Beneficiaries Who Were Concurrently Enrolled in a Medicaid Managed Care Program in Two States
    22-A-05-095.01
    We recommend that the Centers for Medicare & Medicaid Services provide States with matched T-MSIS enrollment data that identify Medicaid beneficiaries who were concurrently enrolled in a Medicaid managed care program in two States.
    PROCESS
    CHANGE
    Implementation requires the responsible agency to change a program’s system or procedure.

    Status
    Open Unimplemented
    Issued to CMS
    09/19/2022
    Audit Report
    A-05-20-00025
  • 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

    Long-Term Trends of Psychotropic Drug Use in Nursing Homes
    23-E-07-003.02
    CMS 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.
    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