Unimplemented Recommendations

The OIG's Top Unimplemented Recommendations: Solutions To Reduce Fraud, Waste, and Abuse in HHS Programs is an annual publication of the Department of Health and Human Services, Office of Inspector General. In this edition, we focus on the top 25 unimplemented recommendations that, in OIG’s view, would most positively affect HHS programs in terms of cost savings, program effectiveness and efficiency, and public health and safety if implemented.

OIG's Top Unimplemented Recommendations: Solutions To Reduce Fraud, Waste, and Abuse in HHS Programs: August 2020

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• OIG's Top Unimplemented Recommendations Overview
  1. CMS should take actions to ensure that incidents of potential abuse or neglect of Medicare beneficiaries are identified and reported.
  2. CMS should reevaluate the inpatient rehabilitation facility (IRF) payment system, which could include seeking legislative authority to make any changes necessary to more closely align IRF payment rates and costs.
  3. CMS should seek legislative authority to comprehensively reform the hospital wage index system.
  4. CMS should seek legislative authority to implement least costly alternative policies for Part B drugs under appropriate circumstances.
  5. CMS should provide consumers with additional information about hospices’ performance via Hospice Compare.
  6. CMS should continue to work with the Accredited Standards Committee X12 to ensure that medical device-specific information is included on claim forms and require hospitals to use certain condition codes on claim forms for reporting device replacement procedures.
  7. CMS 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.
  8. CMS should provide targeted oversight of MAOs that had risk-adjusted payments resulting from unlinked chart reviews for beneficiaries who had no service records in the 2016 encounter data.
  9. CMS should require MAOs to include ordering and referring provider identifiers for applicable records in the encounter data.
  10. 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.
  11. CMS should ensure that States’ reporting of national Medicaid data is complete, accurate, and timely.
  12. CMS should collaborate with partners to develop strategies for improving rates of followup care for children treated for ADHD.
  13. CMS should develop policies and procedures to improve the timeliness of recovering Medicaid overpayments and recover uncollected amounts identified by OIG’s audits.
  14. CMS should identify States that have limited availability of behavioral health services and develop strategies and share information to ensure that Medicaid managed care enrollees have timely access to these services.
  15. ACF should improve access to appropriate mental health treatment services for unaccompanied children and take all reasonable steps to minimize the time that they remain in ORR’s custody.
  16. ACF should develop a comprehensive strategy to improve States’ compliance with requirements related to treatment planning and medication monitoring for children prescribed psychotropic medication.
  17. ACL should determine whether it can allocate its funds differently or seek additional department funding or resources to conduct required onsite compliance reviews of independent living programs.
  18. FDA should ensure effective and timely processes related to food facility inspections and food recalls.
  19. IHS should develop and implement a staffing program for recruiting, retaining, and transitioning staff and leadership to remote hospitals.
  20. IHS should work with hospitals to ensure that they follow the Indian Health Manual when prescribing and dispensing opioids.
  21. IHS should increase oversight of IT systems by IHS management.
  22. NIH should continue to build on its efforts to identify and mitigate potential foreign threats to research integrity.
  23. HHS should develop departmentwide objectives and a strategic framework for responding to international public health emergencies.
  24. HHS should ensure that all future web application developments incorporate security requirements from an industry recognized web application security standard.
  25. CMS and HRSA should ensure that States can pay correctly for 340B-purchased drugs billed to Medicaid, by requiring claim-level methods to identify 340B drugs and sharing the official 340B ceiling prices.