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OIG kidney-transport cost audit identifies unallowable reporting

OIG identified $428,325 in unallowable kidney-transportation costs among selected independent organ procurement organizations and separate preparation or transport deficiencies at four OPOs. CMS agreed with recovery and education recommendations. Agreement with the recommendations does not establish that recovery has occurred.

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What happened

OIG’s report A-09-24-03009, issued September 23 and posted September 28, examined kidney-transportation reporting and organ transport at 43 selected independent organ procurement organizations. It found $188,147 in improperly allocated or insufficiently supported costs reported by 21 OPOs and another $240,178 reported by 26 OPOs, totaling $428,325 in unallowable costs. Those groups fall within the 43 reviewed organizations and should not be added together as 47 separate OPOs. Four OPOs also failed requirements for organ preparation and transport.

OPOs coordinate procurement, preservation and transportation, and the audit followed concerns about wide variation in reported transportation costs and ineffective practices resulting in lost or damaged organs. OIG recommended that CMS instruct the Medicare administrative contractor to recover the questioned costs through cost-report adjustments and provide additional education. CMS concurred with both recommendations. The report identifies financial-reporting and handling concerns, but does not establish organ harm at every reviewed OPO or confirm completed collections. Cost allocation, supporting records and actual transport practices are distinct parts of the resulting control review.

Scope and timing

Authority status
Final
Applicability
Operationally relevant
Audience
Health systems, Provider networks
Jurisdiction
Federal

Why it matters

The action identifies a control failure relevant to provider, payer or vendor oversight. Its procedural status must be kept separate from any allegation.

Case details

agencies
HHS OIG, CMS
entities
Selected independent organ procurement organizations
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

Complete edition and supplemental material

This finding in the complete approved report →

Regulatory horizons, CIA trends and implementation trackers remain in the full report.

Read the entire Enforcement Briefing report →

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