OPO accountability dossier

Donor Alliance

CORSCMS Tier 1

Colorado and most of Wyoming (OPTN Region 8)

CMS performance & status

Shown solid blue (Tier 1) on the CMS 2025 OPO Tier Status map based on 2023 performance data; OPO name and code CORS confirmed in the document's OPO code table.

This OPO is graded Tier 1 (2025 (data year 2023)) under the CMS Conditions for Coverage outcome measures. Tier 1 is the top-performing band, automatically recertified.

CMS QCOR 2025 Maps of OPO DSAs and Tier Status

Findings naming this OPO (5)

Money trail (3)

OPOs hold board seats and reported financial stakes in tissue processors (per reform-group analysis of OPO 990s)

AlloSource board (executives from Donor Alliance, Iowa Donor Network, Mid-America Transplant, ConnectLife, Gift of Hope); MTF Biologics board (Midwest Transplant Network, LifeShare of Oklahoma, New Jersey Sharing Network)

A published analysis by Organ Donation Reform (costlyeffects.organdonationreform.org), citing the OPOs' own IRS Form 990 filings on ProPublica, states that executives from five named OPOs sit on AlloSource's board and that these OPOs hold ownership stakes in AlloSource ranging from $8 million to $26.4 million, and that executives from three additional named OPOs sit on the MTF Biologics board. This is an advocacy-group compilation derived from public 990 data, not a government finding; the underlying per-OPO 990 figures should be independently confirmed.

Tissue Donation & Processing — The Costly Effects of an Outdated Organ Donation System (Organ Donation Reform), citing OPO IRS Form 990s

Surveyed OPOs reported dozens of outside-employment, board, and financial conflicts (2015-2023)

MTN, LifeShare, Donor Alliance, TN/NM Donor Services, LifeCenter, Gift of Life Donor Program, Versiti (OPOs)

The June 2025 Senate Finance staff report tabulated conflicts each OPO reported for 2015-2023, including: MTN (20 outside-employment, 2 board, 1 shareholder/investment); LifeShare (22 outside-employment, 8 board, 3 family); Donor Alliance (7 outside-employment, 8 board); TN/NM Donor Services (2 outside-employment, 2 board); LifeCenter (53 outside-employment plus 18 financial conflicts); Gift of Life Donor Program (8 outside-employment, 7 board, 5 financial); Versiti asserted it had no conflicts. The report notes it is unclear whether these were actual or potential conflicts or how they were reviewed.

Operation Transplant Staff Report (Senate Committee on Finance, June 2025), p.16

Several OPOs hold multimillion-dollar equity stakes in a nonprofit tissue processor (AlloSource), per 990s

Donor Alliance, Iowa Donor Network, Mid-America Transplant, ConnectLife, Gift of Hope (re: AlloSource, EIN 84-1327507)

A reform-advocacy review citing the organizations' IRS Form 990 filings (via ProPublica) reports that five OPOs — Donor Alliance, Iowa Donor Network, Mid-America Transplant, ConnectLife, and Gift of Hope — hold equity stakes in AlloSource ranging from about $8 million to $26.4 million, with executives from those OPOs sitting on AlloSource's board.

Organ Donation Reform, "Tissue Donation & Processing" (citing OPO IRS Form 990 filings via ProPublica)

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

Reported OPO conflicts of interest concentrated in outside employment and outside board memberships, 2015-2023

LifeCenter Organ Donor Network; LifeShare Network; Midwest Transplant Network; Donor Alliance; Gift of Life Donor Program (and other surveyed OPOs)

The Senate Finance Committee 'Operation Transplant' report tabulated conflicts OPOs reported for 2015-2023, dominated by outside-employment and outside-board-membership conflicts: e.g., LifeCenter reported 53 outside-employment conflicts plus 18 financial conflicts; Midwest Transplant Network 20 outside-employment and 2 board conflicts; LifeShare 22 outside-employment and 8 board conflicts; Donor Alliance 7 outside-employment and 8 board conflicts; Gift of Life Donor Program 8 outside-employment, 7 board-service, and 5 financial conflicts. The report criticized the disclosures as vague and inconsistently reviewed.

Operation Transplant staff report (Senate Finance Committee), 'Types and Numbers of Reported Conflicts'


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.