OPO accountability dossier

OneLegacy

CAOPCMS Tier 3

Seven-county greater Los Angeles area, Southern California (OPTN Region 5)

CMS performance & status

CMS 2023 OPO Interim Annual Public Aggregated Performance Report, Table 5b (Donation and Transplant Rates, 2021): donation rate 9.30 (UL 95% CI 9.96) and age-adjusted transplant rate below median cutoff; CY2021 tier column = 3.

This OPO is graded Tier 3 (2023 (CY2021 assessment)) under the CMS Conditions for Coverage outcome measures. Tier 3 is below the median on a required measure — the band CMS deems out of compliance and eligible for decertification.

CMS 2023 OPO Interim Annual Public Aggregated Performance Report (CY2021 assessment)

Findings naming this OPO (15)

Investigation (3)

HHS-OIG audit found OneLegacy overstated Medicare reimbursement by ~$297,000 with unallowable/unsupported costs

OneLegacy

A 2010 HHS Office of Inspector General audit (Report A-09-08-00033) found that OneLegacy did not fully comply with Medicare requirements for reporting organ-acquisition overhead and administrative/general costs in its FY 2006 cost report. Of $3.2 million reviewed, $531,000 was improper — $291,000 unallowable and $240,000 unsupported — leading OneLegacy to overstate its Medicare reimbursement by an estimated $297,000.

HHS-OIG: Review of OneLegacy's Reported FY 2006 Organ Acquisition Overhead Costs (A-09-08-00033)

HHS-OIG: OneLegacy charged Medicare for Rose Parade, deferred comp, lobbying

OneLegacy (Los Angeles OPO); HHS Office of Inspector General

An HHS-OIG audit (A-09-08-00033) of OneLegacy's FY2006 cost report found that of $3,157,740 reviewed, $531,460 was questioned: $290,968 unallowable plus $240,492 unsupported. Itemized unallowable costs were Rose Parade $153,513 (including $16,990 for Rose Parade seats and Rose Bowl game tickets), deferred compensation $64,558, donations and gifts $44,003, lobbying $15,000, and entertainment $4,737. OneLegacy had incurred $327,278 total in Rose Parade/Rose Bowl costs.

HHS-OIG — Review of OneLegacy's Reported Fiscal Year 2006 Organ Acquisition Overhead Costs and Administrative and General Costs (A-09-08-00033)

OneLegacy CEO compensation exceeded $1 million; revenue topped $142 million

OneLegacy (Los Angeles OPO)

Per the IRS Form 990 posted on ProPublica Nonprofit Explorer, OneLegacy reported total revenue of $142,795,454 and total expenses of $128,676,640 for fiscal year 2024, with the Chief Executive Officer role compensated $1,011,953 (plus $139,130 in other benefits), down from $1,116,150 the prior fiscal year. The figures illustrate the scale of nonprofit OPO budgets and executive pay funded substantially through Medicare reimbursement.

ProPublica Nonprofit Explorer — OneLegacy IRS Form 990 (EIN 95-3138799)

Money trail (10)

OneLegacy (largest US OPO): $142.8M revenue, $217.3M assets, CEO paid ~$1.01M (FY2024 Form 990)

OneLegacy (Los Angeles OPO; EIN 95-3138799)

Per its fiscal-year-2024 IRS Form 990 (extracted on ProPublica Nonprofit Explorer), OneLegacy, the federally designated organ procurement organization for greater Los Angeles, reported total revenue of $142,795,454 and total assets of $217,331,658. The organization's Chief Executive Officer role received total reportable compensation of $1,011,953 for the year. Revenue grew from $105.5M (FY2022) to $124.6M (FY2023) to $142.8M (FY2024).

OneLegacy - Nonprofit Explorer, ProPublica (IRS Form 990, FY2024)

HHS-OIG: OneLegacy charged ~$531K in unallowable/unsupported costs to its Medicare organ-acquisition cost center (FY2006 cost report)

HHS Office of Inspector General / OneLegacy

An HHS-OIG audit (report A-09-08-00033, issued January 28, 2010) reviewed OneLegacy's FY2006 Medicare organ-acquisition overhead and administrative/general costs. Of $3.2M reviewed, OIG found $290,968 of unallowable costs and $240,492 of unsupported costs (~$531K combined), and estimated OneLegacy overstated its Medicare reimbursement by ~$297,000. OIG recommended a revised cost report and improved cost-reporting procedures.

Review of OneLegacy's Reported FY2006 Organ Acquisition Overhead and A&G Costs (HHS-OIG A-09-08-00033)

OneLegacy: >$500K of cost-reported spending flagged as unallowable/unsupported (incl. parade, football tickets, lobbying); ~31% organ-recovery rate cited by reform advocates

OneLegacy (Los Angeles OPO)

Published oversight/reform documentation states OneLegacy 'misspent more than half a million taxpayer dollars on unallowable or poorly documented items - including football tickets, parade expenses, and lobbying costs - according to a government audit,' tracing to the HHS-OIG FY2006 cost-report audit (~$531K of unallowable/unsupported costs, including Rose Parade, lobbying, meals and entertainment). The same documentation cites a University of Pennsylvania analysis (2012-2014) reporting OneLegacy recovered organs from roughly 31% of potential donors. The two figures derive from different periods and sources and are presented together by advocates; the underlying audit and analysis are public record.

Oversight Gaps and Conflicts - The Costly Effects of an Outdated Organ Donation System (citing HHS-OIG audit and UPenn OPO analysis)

OneLegacy executive-compensation pool: ~$5.18M total officer/key-employee compensation in a single year (FY2024 Form 990)

OneLegacy (Los Angeles OPO; EIN 95-3138799)

Beyond the single CEO figure, OneLegacy's fiscal-year-2024 IRS Form 990 reports aggregate 'Executive Compensation' (officers, directors, trustees and key employees) of $5,176,629 - about 4.0% of total expenses for the year - per the extracted data on ProPublica Nonprofit Explorer. Individual reported figures by role include the CEO (~$1.01M), the Chief Information Officer role, and two medical-director roles, among others.

OneLegacy - Nonprofit Explorer, ProPublica (IRS Form 990, FY2024, extracted executive compensation)

Largest OPO (OneLegacy) reported ~$143M revenue (2024); CEO compensation over $1M

OneLegacy (Southern California OPO), EIN 95-3138799

Per IRS Form 990 data on ProPublica Nonprofit Explorer, OneLegacy reported total revenue of $142,795,454 in fiscal 2024 (up from $97.8M in 2021), and the Chief Executive Officer role received $1,011,953 in compensation in 2024.

OneLegacy, IRS Form 990 via ProPublica Nonprofit Explorer (EIN 95-3138799)

The self-described largest OPO is a $140M+ nonprofit with $200M+ in assets and seven-figure CEO pay

OneLegacy (Los Angeles OPO), EIN 95-3138799

OneLegacy, which describes itself as the nation's largest organ procurement organization (serving the Los Angeles region), reported total revenue of about $142.8M and total assets of about $217.3M in FY2024 per its IRS Form 990, up from about $124.6M revenue / $141.1M assets in FY2023. Its highest-paid executive, the chief executive officer, received roughly $1.15M in total compensation in FY2024.

OneLegacy - Nonprofit Explorer, ProPublica (IRS Form 990)

HHS-OIG audit found a major OPO charged Medicare for lobbying, Rose Parade and entertainment costs

OneLegacy (Los Angeles OPO) - HHS-OIG audit A-09-08-00033

An HHS Office of Inspector General audit (report A-09-08-00033, issued Jan. 28, 2010) of OneLegacy's reported FY2006 organ-acquisition overhead and administrative/general costs found that of about $3.2M reviewed, roughly $291,000 were unallowable costs and about $240,000 were unsupported. The unallowable costs included items reported as incurred for the Rose Parade, deferred compensation, donations and gifts, lobbying, meals and entertainment, resulting in an estimated Medicare overstatement of about $297,000.

HHS-OIG, Review of OneLegacy's Reported FY2006 Organ Acquisition Overhead Costs (A-09-08-00033, Jan. 2010)

OneLegacy (Los Angeles), the nation's largest OPO, reported $142.8M revenue and ~$1.01M CEO pay (FY2024)

OneLegacy (EIN 95-3138799)

OneLegacy, the federally designated organ procurement organization for greater Los Angeles, reported total revenue of $142,795,454 for the fiscal year ending Dec. 31, 2024 on its IRS Form 990. Its Chief Executive Officer reported base/reportable compensation of $1,011,953 plus $139,130 in other compensation for that year. The prior year (FY2023) revenue was $124,586,536.

OneLegacy — IRS Form 990, ProPublica Nonprofit Explorer (EIN 95-3138799)

HHS-OIG (2010): OneLegacy overstated Medicare reimbursement by ~$297K on its FY2006 cost report

OneLegacy / CMS (Medicare)

HHS-OIG report A-09-08-00033 (issued Jan. 28, 2010) found OneLegacy did not fully comply with Medicare requirements for reporting selected organ-acquisition overhead and administrative/general costs on its FY2006 Medicare cost report. Of $3.2 million reviewed, the OIG identified roughly $291,000 in unallowable and $240,000 in unsupported costs, and concluded OneLegacy overstated its Medicare reimbursement by an estimated $297,000.

HHS-OIG report A-09-08-00033 (Jan. 28, 2010)

Congressional/OIG records cite wasteful spending by OPOs (LA OPO; California Transplant Donor Network) that triggered no decertification

OneLegacy (Los Angeles OPO) and California Transplant Donor Network / HHS-OIG / Senate Finance Committee

The bipartisan Senate Finance Committee (Grassley-Wyden) oversight letter to HHS (Oct. 23, 2020) grounded its concerns in HHS-OIG cost-report reviews of OPOs, expressly citing OIG audits of OneLegacy (A-09-08-00033) and the California Transplant Donor Network (A-09-09-00087) and the OIG finding that OPO lobbying expenses are 'unallowable' because they are 'not related to patient care.' Those underlying OIG audits identified unallowable/unsupported overhead and administrative costs charged to Medicare. (Specific itemized examples such as sports/Rose Bowl-related and event expenses appear in the underlying OIG audit reports rather than in the letter itself.)

Senate Finance Committee (Grassley-Wyden) letter to HHS on OPO oversight (Oct. 23, 2020)

Consent gap (2)

Individual OPOs self-reported pancreata-for-research increases ranging from 10% to 6,400% in a single year (2021-2022)

Donor Alliance; Lifebanc; Indiana Donor Network; OneLegacy; Texas Organ Sharing Alliance; and other surveyed OPOs

In responses cited by the Senate Finance Committee 'Operation Transplant' report, OPOs reported widely varying single-year (2021-2022) increases in pancreata placed for research: Donor Alliance reported a 6,400% increase, Lifebanc 2,000%, Indiana Donor Network 747%, Lifeline of Ohio 392%, OneLegacy 390%, LifeQuest 267%, Texas Organ Sharing Alliance 216%, Mid-America Transplant 56%, NJ Sharing Network 89%, and Kentucky Organ Donor Affiliates 10%. The report flags these increases as evidence of possible gaming of CMS performance metrics.

Operation Transplant: Examining the Need for Oversight in the Organ Donation System (Senate Finance Committee staff report), footnote 30

HHS-OIG: OneLegacy claimed unallowable and unsupported overhead costs to Medicare in FY2006

OneLegacy (organ procurement organization); Centers for Medicare & Medicaid Services (CMS)

An HHS Office of Inspector General audit (A-09-08-00033, issued 2010) found that of $3.2 million of FY2006 organ-acquisition overhead and administrative costs reviewed, about $531,000 did not comply with Medicare requirements ($291,000 unallowable and $240,000 unsupported), and that OneLegacy overstated its Medicare reimbursement by an estimated $297,000. OIG recommended a revised cost report and improved cost-reporting procedures.

Review of OneLegacy's Reported Fiscal Year 2006 Organ Acquisition Overhead Costs and Administrative and General Costs (HHS-OIG, A-09-08-00033)


Every item is institution-level public record, source-linked; no patient, donor, or family is named. A Tier or finding here repeats the government's own assessment of an organization holding a public monopoly. Back to OrganWatch.