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As of January 31, 2023, there are 4842 open recommendations that still need to be addressed. 473 of these are priority recommendations, those that we believe warrant priority attention. Learn more about our priority designation on our Recommendations page.

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1 - 20 of 130 Recommendations, including 20 Priority Recommendations

Medicare Advantage: Plans Generally Offered Some Supplemental Benefits, but CMS Has Limited Data on Utilization

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2 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The Administrator of CMS should clarify guidance to MA plans on the extent to which encounter data submissions must include data on the utilization of supplemental benefits. (Recommendation 1)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Centers for Medicare & Medicaid Services The Administrator of CMS should take actions to address circumstances where submitting encounter data for supplemental benefits is challenging for MA plans, such as when a given benefit lacks an applicable procedure code. Such actions may include the creation of new procedure codes or a new data submission format. (Recommendation 2)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Medicare: CMS Needs to Address Risks Posed by Provider Enrollment Waivers and Flexibilities

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4 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The Administrator of CMS should conduct fingerprint-based criminal background checks for high-risk provider types who enrolled during the COVID-19 public health emergency, such as when CMS revalidates these providers' information. (Recommendation 1)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Centers for Medicare & Medicaid Services The Administrator of CMS should develop policies and procedures to postpone rather than waive fingerprint-based criminal background checks during future emergencies. (Recommendation 2)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Centers for Medicare & Medicaid Services The Administrator of CMS should develop and implement a plan for conducting provider enrollment revalidations to ensure providers are revalidated prior to the end of their 3- to 5-year revalidation cycles, prioritizing moderate- and high-risk provider types. (Recommendation 3)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Centers for Medicare & Medicaid Services The Administrator of CMS should evaluate waivers and flexibilities for provider enrollment, including related oversight challenges, and address any opportunities for improvement. This evaluation could consider targeting provider enrollment waivers and flexibilities to maintain requirements for provider types CMS considers high risk—including DMEPOS suppliers—and opportunities to track and communicate to program integrity contractors information about each waiver and flexibility providers enrolled under. (Recommendation 4)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Abuse and Neglect: CMS Should Strengthen Reporting Requirements to Better Protect Individuals Receiving Hospice Care

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1 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The CMS administrator should require, for individuals in hospice care, immediate reporting of all abuse and neglect allegations involving all perpetrators—including those not affiliated with the hospice—to the hospice administrator, a state survey agency, and other appropriate authorities. (Recommendation 1)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Medicare Telehealth: Actions Needed to Strengthen Oversight and Help Providers Educate Patients on Privacy and Security Risks

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3 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The Administrator of CMS should develop an additional billing modifier or clarify its guidance regarding billing of audio-only office visits to allow the agency to fully track these visits. (Recommendation 1)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Centers for Medicare & Medicaid Services The Administrator of CMS should require providers to use available site of service codes to indicate when Medicare telehealth services are delivered to beneficiaries in their homes. (Recommendation 2)
Open – Partially Addressed

In the Calendar Year 2023 Medicare Physician Fee Schedule Final Rule, CMS finalized use of two available site of service codes to indicate where telehealth services are delivered. On the 152nd day after the end of the public health emergency, providers will be required to use one of these two codes to indicate whether a telehealth service is delivered in a beneficiary's home or other location, such as an office or clinic. These required site of service codes partially address our recommendation. We will close this recommendation once CMS implements these codes after the public health emergency

Centers for Medicare & Medicaid Services The Administrator of CMS should comprehensively assess the quality of Medicare services, including audio-only services, delivered using telehealth during the public health emergency. Such an assessment could include leveraging evidence from related efforts led by other HHS agencies. (Recommendation 3)
Open

In November 2022, CMS said they no longer agree with this recommendation because they do not have a measure to assess quality, and cannot consider developing or re-specifying such a measure due to budget restraints. Further, they have no planned actions for this recommendation. We maintain the importance of assessing the quality of telehealth services given that providers receive the same payment whether or not telehealth services are provided via video or audio-only during the public health emergency. Also, it is important for CMS to study the quality of telehealth services to ensure that

COVID-19 in Nursing Homes: CMS Needs to Continue to Strengthen Oversight of Infection Prevention and Control

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3 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The Administrator of CMS should provide additional guidance in the State Operations Manual on making scope and severity determinations for IPC-related deficiencies. (Recommendation 3)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Centers for Medicare & Medicaid Services The Administrator of CMS should collect infection preventionist staffing data and use these data to determine whether the current infection preventionist staffing requirement is sufficient. (Recommendation 2)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Centers for Medicare & Medicaid Services The Administrator of CMS should establish minimum infection preventionist training standards. (Recommendation 1)
Open

When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Medicaid: CMS Should Assess Effect of Increased Telehealth Use on Beneficiaries' Quality of Care

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2 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The Administrator of CMS should collect and analyze the information needed to assess the effect delivering services via telehealth has on the quality of care Medicaid beneficiaries receive. (Recommendation 1)
Open

In October 2022, CMS said information is not available to carry out an assessment and reiterated the agency does not have the authority to modify the specifications of Core Sets' measures for which it is not the measurement steward. As we noted in our report, this is not the only approach that CMS could take. In particular, CMS could develop a plan for reporting a measure for which it is the steward; for example, reporting on any effect that service delivery (for example, in-person or via telehealth) has on the quality of care Medicaid beneficiaries receive. Additionally, where CMS is not the

Centers for Medicare & Medicaid Services The Administrator of CMS should determine, based on the results of its initial assessment, whether further assessments of the effect delivering services via telehealth has on the quality of care Medicaid beneficiaries receive are warranted, for the purposes of developing guidance to assist states in making telehealth coverage and payment decisions. (Recommendation 2)
Open

In October 2022, CMS said information is not available to carry out the initial assessment on which to determine the need for additional guidance. As noted in our report, we identified efforts in four of six selected states to assess the quality of care provided via telehealth. These state-based efforts may merit further agency investigation. GAO maintains it is crucial for CMS to collect and analyze information to assess the effect that delivering services via telehealth has on the quality of care Medicaid beneficiaries receive. Additionally, the results of these initial assessments should

Medicaid Behavioral Health: CMS Guidance Needed to Better Align Demonstration Payment Rates with Costs and Prevent Duplication

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2 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The Administrator of CMS should issue clear and consistent written guidance that highlights the importance of rebasing CCBHC payment rates based on actual costs and provides more detailed information on when and how states should rebase their rates, such as suggested time frames. (Recommendation 1)
Open

HHS concurred with this recommendation and as of January 2023, HHS indicated that CMS was in the process of updating question and answer documents posted to Medicaid.gov to provide clearer written guidance to states regarding the rebasing of CCBHC payment rates. GAO is keeping this recommendation open until CMS completes its planned updates.

Centers for Medicare & Medicaid Services The Administrator of CMS should provide clear and consistent written guidance to states on how to avoid potential duplication between Medicaid CCBHC payments and other Medicaid payments. (Recommendation 2)
Open

HHS concurred with this recommendation and as of January 2023, HHS indicated that CMS was in the process of updating question and answer documents posted to Medicaid.gov to provide clearer written guidance to states on how to avoid potential duplication between Medicaid CCBHC payments and Medicaid payments when clinics are also certified as additional provider types. GAO is keeping this recommendation open until CMS completes its planned updates.

Federal Rulemaking: Selected Agencies Should Fully Describe Public Comment Data and Their Limitations

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1 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The Administrator of CMS should fully describe available public comment data, including any limitations, to external users of the data. This should include coordination with GSA, as the manager of Regulations.gov, as appropriate. (Recommendation 3)
Open

In March 2022, CMS provided an excerpt of boilerplate language it uses in rulemaking documents that addressed some of the limitations highlighted in our report, such as the agency's comment-posting practices for duplicate comments. However, it does not address how CMS uses public comments or specific details regarding required or voluntary elements of personally identifiable information. CMS also stated that it plans to provide a formal corrective action plan by December 31, 2022. We will continue to monitor CMS's efforts in this area.

Medicaid Home- and Community-Based Services: Evaluating COVID-19 Response Could Help CMS Prepare for Future Emergencies

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2 Open Recommendations
Agency Recommendation Status
Centers for Medicare & Medicaid Services The CMS Administrator should develop procedures to monitor temporary changes to Medicaid HCBS programs during public health emergencies. This should include procedures for collecting and analyzing data during emergencies on the effects of these changes. (Recommendation 1)
Open

As of September 2022, HHS reported that CMS is in the process of developing procedures for monitoring temporary changes to Medicaid HCBS programs during public health emergencies. Monitoring indicators will include (1) fluctuations in the number of beneficiaries served and (2) events reported in state incident management systems, such as unexpected deaths. When we confirm CMS has these procedures in place, we will provide updated information.

Centers for Medicare & Medicaid Services The CMS Administrator should evaluate the temporary changes to Medicaid HCBS programs after the COVID-19 emergency and develop corrective action plans to address any opportunities for improvement it identifies. (Recommendation 2)
Open

As of September 2022, HHS reported that CMS will evaluate temporary changes to Medicaid HCBS programs after the COVID-19 public health emergency and develop corrective action plans as needed. The agency also noted CMS's efforts to (1) consider the risks of approving or denying requests for temporary changes, (2) revise templates and instructions for requesting temporary changes, and (3) present on the landscape of temporary changes that states used during the COVID-19 public health emergency. When we confirm CMS has conducted this evaluation, we will provide updated information.

Note: the list of open recommendations for the last report may continue on the next page.

Have a Question about a Recommendation?

For questions about a specific recommendation, contact the person or office listed with the recommendation. For general information about recommendations, contact GAO's Audit Policy and Quality Assurance office at (202) 512-6100 or apqa@gao.gov.