FY 2025 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 budget submission date. In compliance with this law, the Department of Health and Human Services (HHS or the Department) developed this report listing the 767 public recommendations issued by GAO and the HHS OIG that have been open for more than one year as of September 30, 2025. Additionally, this report identifies the 26 recommendations that were closed, unimplemented in Fiscal Year (FY) 2025 either because HHS did not concur or they are no longer valid due to passage of time, program changes, or changes in Office of Management and Budget (OMB) guidance. This is the seventh annual report HHS has completed to comply with this Act.

Background

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 one year old, the Act requires a reconciliation between the agency records and the OIG’s Semiannual Report to Congress (SAR).

As of September 30, 2025, HHS recognized a total of 767 public recommendations that have been open for more than one year (i.e., issued on or before September 30, 2024). Of the 767 open recommendations,

• 324 were issued by GAO during the period July 12, 2002 through September 30, 2024. GAO reports 327 open recommendations for this period. The discrepancy can be traced to timing; GAO notified HHS of closure for three recommendations in Fall but GAO’s report did not reflect this update when GAO sent information to HHS on September 30, 2025.
• 443 were issued by HHS OIG during the period August 1, 2005 through September 30, 2024. OIG reports the same number of Departmental recommendations for this period.¹

Appendix 1: OIG-GAO Open Recommendations contains the list of all open recommendations over a year old. 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 December 2, 2025. The recommendations status for each recommendation is identified as either “In Progress,” when activities are ongoing, or “Awaiting Disposition,” for recommendations HHS has provided updates pending auditor response, as these recommendations are pending auditor validation and close out, or with which HHS has non-concurred. For recommendations with which HHS did not concur or did not implement 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 corrective action to be complete and maintains that the auditors should close the recommendation as implemented. As shown in Figure 1, of the 767 open recommendations, 65.6 percent are “In Progress.” The remaining 34.4 percent are “Awaiting Disposition” and may be closed and removed from future reports once the auditors complete their review of HHS-provided information and updates.

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

In accordance with OMB Revised Circular A-50, “Audit, Inspection, or Evaluation 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. HHS Divisions successfully closed 188 recommendations that were over a year old in FY 2025. Table 1 presents the changes in the number of recommendations this year compared to the previous year.

*Includes all Divisions with less than 20 open recommendations at the end of FY 2025.

HHS is directing attention to aged recommendations that have not been closed by the auditor. With over 40 percent of recommendations over 5 years old, detailed in Figure 2 below, targeting this subset of open recommendations would greatly reduce the Department’s total open recommendation population. Often, recommendations reach this age because implementation is difficult, involving legislative action, additional resources, drastic programmatic changes, or a combination of complex factors that may be outside the agency’s purview. Additionally, some old recommendations have been superseded by policy and program changes since the auditor issued the original report. In FY 2026, HHS plans to continue to work with OIG and GAO to identify the latter type of recommendation and work collaboratively to close these recommendations, or better understand what the agency needs to do to close out such recommendations in future reporting years.

Figure 2: Recommendations by Years Open

GAO and OIG also identify top issues and recommendations (known as Priority Recommendations or Top Unimplemented Recommendations, respectively)² they believe could help significantly improve HHS’s program operations.  Appendix 1 includes the 47 GAO Priority Recommendations or OIG Top Unimplemented Recommendations among the open recommendations; of those 47 priority recommendations, 16 are awaiting disposition and the remaining 31 are in progress.

Read the HHS GAO-IG Act Report.

Footnotes

¹ OIG no longer publishes historical unimplemented recommendations in the SAR. As a result, HHS reconciled with OIG’s internal recommendation tracker. tracker.

² GAO publishes an annual report highlighting priority open recommendations for HHS. The 2025 report can be found here: GAO-25-108032. OIG updates the Recommendation Tracker on their webpage annually to identify OIG's Top Unimplemented Recommendations.