Federal investigation found dozens of troubling cases, including potential donors who may not have been dead when organ procurement preparations began
By Lucretia Hughes Klucken
LEXINGTON, Ky. — Health and Human Services Secretary Robert F. Kennedy Jr. announced Wednesday that the federal government has begun decertifying a Kentucky-based organ procurement organization following investigations that uncovered persistent safety failures and cases involving potential donors who showed signs of life.
The action targets Network for Hope, the federally designated nonprofit responsible for coordinating organ donations across Kentucky and portions of Indiana, Ohio and West Virginia.
The Centers for Medicare and Medicaid Services determined that the organization no longer meets the federal requirements necessary to operate as a qualified organ procurement organization.
“Americans who choose to become organ donors deserve a system that honors their gift and protects every patient,” Kennedy said. “Organizations that repeatedly fail to meet federal standards and put patients at risk will be held accountable.”
The findings are horrifying.
A federal review examined 351 cases between 2021 and 2024 in which organ donation had been authorized but was ultimately not completed. Investigators identified concerning features in 103 cases, representing nearly 30% of those reviewed.
Seventy-three patients displayed neurological signs that investigators said were incompatible with proceeding toward organ donation.
Federal officials also found that some potential donors may not have been deceased when the organ procurement process was initiated.
Read that again.
These were not simply paperwork mistakes involving people unquestionably dead. These were patients whose cases had entered the organ donation process even though some were showing neurological signs of life.
That does not mean organs were removed from living patients in the cases cited by HHS. The planned recoveries were stopped. But the fact that the process advanced as far as it did should terrify every American.
One of the most alarming allegations stems from a 2021 case involving a Kentucky man hospitalized after a drug overdose. According to federal officials and reporting on the case, the organization’s predecessor allegedly pressured hospital personnel to continue preparing for the withdrawal of life support and organ recovery despite indications that the patient was waking up.
The procedure was canceled.
The man survived.
Organ procurement organizations do not have the legal authority to declare a patient dead. That responsibility belongs to the treating hospital and its physicians. However, procurement organizations coordinate the donation process, evaluate potential donors, work with families and arrange the recovery and transportation of organs.
That makes communication, accurate neurological evaluation and an unwavering commitment to patient safety absolutely essential.
HHS investigators cited poor neurological assessments, inadequate coordination with medical teams, questionable consent practices and the misclassification of causes of death, particularly in cases involving drug overdoses.
Patients suffering from overdoses or severe neurological injuries may be unable to speak for themselves. Their families may be frightened, grieving and depending entirely on doctors and donation professionals to tell them the truth.
There can be no room for pressure, shortcuts or assumptions.
A person is not a collection of spare parts. Until death has been properly and independently determined, that person is a patient whose life must be protected.
Organ donation is one of the greatest gifts one human being can offer another. Thousands of Americans receive lifesaving transplants each year because individuals and families make that selfless decision.
But the entire system depends on trust.
Donors must trust that doctors will fight for their lives first. Families must trust that conversations about donation will never interfere with decisions concerning treatment. Transplant recipients must trust that every organ was obtained ethically and legally.
When that trust is broken, the consequences extend far beyond one organization.
After the Kentucky case became public, reports indicated that people across the country removed themselves from organ donor registries. That reaction is understandable, but it also threatens patients waiting for lifesaving hearts, kidneys, livers and lungs.
The way to preserve organ donation is not to hide failures. It is to expose them, correct them and hold responsible organizations accountable.
Kennedy called Network for Hope a “bad apple” and accused it of persistent safety failures despite repeated federal oversight and opportunities to improve.
The organization strongly disputes the government’s conclusions and said it intends to appeal. Network for Hope maintains that it follows federal policies and has implemented additional safeguards requiring the donation process to stop when medical personnel raise concerns.
Those arguments will be examined during the administrative appeals process.
Under the federal notice, Network for Hope’s Medicare agreement is scheduled to terminate Nov. 3. The government may temporarily extend the agreement to allow organ procurement services to transition safely to another organization.
The service area will not be opened for competition until the appeals process is completed or Network for Hope abandons its appeal rights.
That transition must be handled carefully. More than 100,000 Americans remain on the national transplant waiting list, and any interruption could place additional lives at risk.
Accountability and continuity are both necessary. Protecting prospective donors cannot mean abandoning patients awaiting transplants.
The broader concern is that these findings may not be limited to one organization.
Network for Hope is one of approximately 55 organ procurement organizations operating across the United States. Each is assigned a geographic region and relies heavily on federal certification and reimbursement.
For years, critics have warned that parts of the transplant system lacked transparency, meaningful competition and consistent accountability.
Kennedy launched a larger reform initiative in 2025 after the Health Resources and Services Administration reviewed organ procurement cases and identified patients showing signs of life. HHS said a previous investigation had been closed without adequate action during the Biden administration.
Federal regulators have since taken enforcement action against another organ procurement organization in Florida, citing unsafe practices, poor training, chronic underperformance and other failures.
Those actions suggest the Kentucky findings may be part of a larger oversight problem that Washington allowed to continue for too long.
Kennedy is right to demand answers.
This issue is not anti-organ donation. It is about protecting the integrity of organ donation.
It is not an attack on the doctors, nurses and coordinators who perform lifesaving work with compassion and professionalism. It is a demand that every organization entrusted with human life meet the highest possible standard.
The system must contain a clear wall between the medical team attempting to save a patient and those responsible for coordinating donation. Death must be determined independently, accurately and without pressure from anyone focused on organ recovery.
Families must receive honest information. Consent must be informed. Every sign of neurological activity must be taken seriously.
And whenever there is doubt, the process must stop.
No transplant statistic, performance measurement or potential organ can ever justify treating a living patient as though death has already occurred.
Kennedy’s action sends an overdue message: The gift of life must never come at the expense of a life that has not ended.
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