OIG kidney-transport cost audit identifies unallowable reporting
Oct 4, 2026 edition · GC-2026-0191 · Published 2026-10-04 · Version 2 · Final
OIG found $428,325 in unallowable kidney-transport costs and preparation or transport deficiencies at four OPOs; CMS concurred with recovery and education recommendations.
What happened
OIG's September 23, 2026 audit, posted September 28, reviewed kidney-transportation cost reporting and organ transport at 43 selected independent organ procurement organizations. Twenty-one OPOs reported $188,147 in improperly allocated or inadequately supported transportation costs, and 26 reported another $240,178 in costs that failed Medicare requirements. The combined unallowable amount was $428,325. The groups should not be added to infer 47 distinct organizations; the report reviewed 43 selected OPOs and describes separate findings.
OIG also identified four OPOs that did not meet Medicare requirements for organ preparation and transport. It recommended that CMS instruct the Medicare administrative contractor to recover the unallowable costs through adjustments to applicable cost reports and provide additional education. CMS concurred with both recommendations. That concurrence is not proof that every adjustment or collection had occurred by October 4, nor is the audit a court judgment. The findings connect accounting support and allocation with physical transport practices, which require separate evidence and control owners.
Scope and timing
- Authority status
- Final
- Applicability
- Operationally relevant
- Audience
- Health systems, Provider networks
- Jurisdiction
- Federal
Why it matters
OPO oversight needs both defensible cost-report allocations and compliant organ preparation and transport, with distinct follow-up for each.
Recommended action
Review kidney-transport cost categories, allocation support and cost-report records, alongside organ-preparation and transport controls. Track actual contractor adjustments separately from recommended recovery.
Case details
- agencies
- HHS OIG, CMS
- entities
- Independent organ procurement organizations included in OIG audit A-09-24-03009
- action Type
- Audit
- event Date
- 2026-09-23
- alleged Conduct
- OIG identified $428,325 in unallowable kidney transportation costs and transport-preparation deficiencies at four OPOs. CMS concurred with recovery and education recommendations. The report was issued September 23 and posted September 28.
- resolution
- OIG audit findings and recommendations, not a court judgment or settlement.
Operational lessons
- Review OPO transport-cost classification, cost-report evidence and transport preparation against the report recommendations.
Sources
- OIG kidney-transport cost audit identifies unallowable reportingOfficial · HHS OIG · 2026-09-23 · Source review 2026-10-04
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