FY 2021 Good Accounting Obligation in Government Act Report

Executive Summary

The Good Accounting Obligation in Government Act (GAO-IG Act or “the Act”; Public Law 115-414) requires each agency to include, in its annual budget justification, a report identifying each public recommendation issued by the Government Accountability Office (GAO) and federal Offices of Inspectors General (OIG), that remains unimplemented for one year or more as of the annual budget justification submission date. In compliance with this law, the Department of Health and Human Services (HHS or the Department) developed this report listing the 850 public recommendations issued by GAO and the HHS OIG that have been open for more than one year as of September 30, 2021. Additionally, this report identifies the 237 closed, unimplemented recommendations with which HHS did not concur or did not implement due to legislative or budgetary constraints.


Congress enacted the GAO-IG Act to enhance transparency into open and unimplemented public recommendations issued by the GAO and agencies’ OIG. In addition to reporting on unimplemented public recommendations over a year old, the Act requires a reconciliation between the agency records and the OIG’s Semiannual Report to Congress (SAR report). To meet the requirements of the Act, this year’s report provides the status of recommendations as of September 30, 2021.

As of September 30, 2021, HHS recognizes a total of 850 public recommendations that have been open for more than one year, i.e., issued on or before September 30, 2020. This includes 6 COVID-19 related recommendations. Of the 850 open recommendations,

  • HHS identified 359 open GAO recommendations issued during the period July 12, 2002 through September 30, 2020 compared to 357 open recommendations reported by GAO for this same time period. This variance (of 2 recommendations) is the result of incomplete records HHS is working to resolve.
  • HHS identified 491 open HHS OIG recommendations issued during the period August 1, 2005 through September 30, 2020 which correspond to the to the 491 open recommendations in the HHS OIG Fall 2021 SAR for this same time period.

For recommendations with which HHS concurred, this report provides timelines for full implementation of the planned corrective actions, as well as updates and constraints as of October 1, 2021 for the recommendations in Appendix 1: OIG-GAO Open Recommendations. These recommendations are considered “In Progress.” For recommendations HHS believes have been implemented, but the auditor lists as open, this report indicates the status as “Awaiting Disposition,” as these recommendations are pending auditor validation and close out. For recommendations with which HHS did not concur or did not implement due to legislative or budgetary constraints and auditors closed, this report identifies the reasons for the “Closed, Unimplemented” status in Appendix 2: OIG-GAO Closed, Unimplemented Recommendations.

The Department continues to make a good faith effort to implement these recommendations. In many cases, HHS determined the required action to be complete and maintains that the auditors should close the recommendation. As shown in Figure 1, of the 850 open recommendations, more than two thirds are “In Progress.” The remaining are “Awaiting Disposition” and may be closed and removed from future reports once the auditors complete their review of HHS-provided information and updates.

Pie chart showing the implementation status of all GAO and OIG public recommendations with 70.9% awaiting disposition , 29.1% in progress

Figure 1: Implementation Status of All GAO and OIG Public Recommendations

In accordance with Office of Management and Budget (OMB) Circular A-50, “Audit Follow Up”, HHS is committed to preparing prompt, responsive, and constructive corrective actions to address OIG and GAO audit report findings and recommendations.  HHS considers audit recommendation follow-up an integral part of sound stewardship. Even in the midst of the Department’s intensive response to the ongoing COVID-19 public health emergency, HHS Divisions successfully closed 158 recommendations that were over a year old in Fiscal Year 2021. Table 1 presents the changes in the number of recommendations since last year’s report.

Table 1: Number of Recommendations Over 1 Year Old by OpDiv/StaffDiv
OpDiv Open at end-of-FY20 Aged to Over 1 Year in FY21 Closed in FY21 Open at end-of-FY21
CMS 451 103 69 485
FDA 62 26 24 64
IHS 56 23 18 61
ACF 29 28 10 47
OCIO 37 5 7 35
NIH 25 17 9 33
ASPR 18 16 2 32
ASFR 22 6 4 24
All other* 53 31 15 69
HHS Total 753 255 158 850
*Includes all OpDivs/StaffDivs with less than 20 open recommendations at the end of FY21.

GAO and OIG also identify top issues and recommendations (known as Priority Recommendations or Top Unimplemented Recommendations, respectively)1 they believe could help significantly improve HHS’s program operations.  Appendix 1 provides the 216 GAO Priority Recommendations or OIG Top Unimplemented Recommendations among the open recommendations; of those 216 priority recommendations, 45 are awaiting disposition and the remaining 171 are in progress.

Read the HHS GAO-IG Act Report.

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