Kentucky Organ Donor Affiliates (KODA)

Congress placed whistleblower account on the record; OPO denied it

Kentucky Organ Donor Affiliates (KODA) / Network for Hope, Inc.

In a written Question for the Record from the July 22, 2025 House Energy & Commerce Oversight & Investigations subcommittee hearing, a subcommittee member asked the OPO's CEO to acknowledge that "multiple whistleblowers have stated that after the doctor in the operating room called the treatment of [the patient] 'inhumane' and refused to proceed," the OPO's leadership "tried to find another doctor that would remove" the patient's organs. In its written response, the OPO (now Network for Hope) denied the allegation. The exchange placed the whistleblower account into the official congressional record.

Network for Hope, Inc. — Additional Questions for the Record, House Energy & Commerce Subcommittee on Oversight & Investigations hearing (July 22, 2025)

HRSA branch chief testified to a pattern of DCD assessment failures at Kentucky OPO

Health Resources and Services Administration (HRSA) / Kentucky Organ Donor Affiliates

At the July 22, 2025 House Energy & Commerce Oversight & Investigations hearing, HRSA's Organ Transplant Branch Chief testified that the agency's investigation of the Kentucky OPO identified a pattern of: failure to recognize neurologic function inconsistent with or unfavorable for donation-after-circulatory-death (DCD) organ recovery on initial assessment or follow-up; failure to work collaboratively with patients' primary medical teams, including potential violations of the separation of roles in patient care; and failure to respect family wishes and safeguard the decision-making authority of legal next of kin.

House Energy & Commerce — Oversight & Investigations Subcommittee Hearing on Organ Procurement and Transplant System Patient Safety (July 22, 2025)

HRSA found about 28% of Kentucky OPO's reviewed cases involved drug intoxication, where neurologic scores can understate true function

Health Resources and Services Administration (HRSA) / Kentucky Organ Donor Affiliates

Per a congressional Question for the Record citing the HRSA report, 27.9% of the Kentucky OPO's reviewed cases involved patients who experienced intoxication from opioids, amphetamines, or cocaine — substances that the QFR notes can produce lower neurologic-assessment scores than a patient actually possesses, raising the risk of premature suitability determinations in overdose cases. The OPO's written response described training and corrective measures it has since adopted.

Network for Hope, Inc. — Additional Questions for the Record, House Energy & Commerce Subcommittee hearing (July 22, 2025)

HHS/HRSA review of Kentucky OPO found 28 cases where patients may not have been deceased when procurement began

Kentucky Organ Donor Affiliates (now Network for Hope)

An HHS/HRSA investigation reviewed roughly 350-351 organ procurement cases handled by the Kentucky OPO (Kentucky Organ Donor Affiliates, since merged into Network for Hope) and found about 73 cases with neurological signs incompatible with donation, of which at least 28 patients may not have been deceased when the procurement process began. HHS reported findings of poor neurologic assessment, questionable consent practices, and inadequate coordination with medical teams, and mandated corrective actions including a root-cause analysis and a formal procedure to halt donation when safety concerns arise.

HHS.gov: HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System

HRSA review found 29.3% of reviewed Kentucky OPO cases had "concerning features"

Health Resources and Services Administration (HRSA); Kentucky Organ Donor Affiliates (now Network for Hope)

In a Division of Transplantation report dated March 24, 2025, HRSA reviewed 351 unique authorized-not-recovered cases with sufficient documentation handled by the Kentucky OPO and found that 103 of them (29.3 percent) had "concerning features," including issues with patient-family interactions, medical and team assessments, recognition of high neurologic function, and documentation of drugs. The OPO, formerly Kentucky Organ Donor Affiliates (KYDA/KODA), now operates as Network for Hope.

HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System (HHS.gov press release)

HRSA found 28 patients may not have been deceased when procurement was initiated

Health Resources and Services Administration (HRSA); Kentucky Organ Donor Affiliates (Network for Hope)

Among the reviewed Kentucky OPO cases, HRSA found that at least 28 patients may not have been deceased at the time organ procurement was initiated, and that 73 patients showed neurological signs the agency described as incompatible with proceeding to donation. HHS characterized the findings as showing the procurement process advanced in cases where patients displayed signs of life.

HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System (HHS.gov press release)

Index DCD case (KYDA-001) survived an attempted withdrawal of life support and procurement

Kentucky Organ Donor Affiliates (KYDA/KODA / now Network for Hope)

Per the House Energy and Commerce Subcommittee on Oversight and Investigations July 22, 2025 hearing memorandum, the index case labeled "KYDA-001" involved a patient who experienced cardiovascular collapse after an unintentional overdose and was slated for donation after circulatory death. The memo states that hospital staff documented improving neurologic function and discomfort, that no additional neurological assessments were documented before proceeding to the operating room, and that after roughly 45 minutes a palliative care physician ended the attempted recovery, documenting that she felt it was "inhumane and unethical" and would not participate. The memo states KYDA-001 survived the attempted withdrawal of life support and procurement.

Memorandum for July 22, 2025 Subcommittee on Oversight and Investigations Hearing (House Energy and Commerce)

HRSA report cited that 27.9% of reviewed Kentucky OPO cases involved drug intoxication

Kentucky Organ Donor Affiliates (KYDA/KODA / now Network for Hope)

In written responses for the July 22, 2025 House Energy and Commerce hearing, a member of Congress stated that the HRSA report noted 27.9 percent of the reviewed Kentucky OPO cases involved patients who experienced intoxication from opioids, amphetamines, or cocaine, a population in which neurologic recovery can be harder to assess because such substances can produce lower neurologic scores than the patient actually possesses.

Written testimony/responses, House Energy and Commerce O&I Hearing, July 22, 2025 (docs.house.gov)

HRSA found a specific OPO pressured families and clinicians to proceed with donation

Network for Hope (formerly Kentucky Organ Donor Affiliates)

A multi-year HRSA investigation into the OPO now named Network for Hope (formerly Kentucky Organ Donor Affiliates, serving Kentucky and parts of neighboring states) found that its employees frequently pressured families to authorize donation, improperly took over cases from physicians, and tried to pressure hospital staff to withdraw life support. HRSA reported reviewing more than 350 cases, with about 70 patients having neurological conditions making them unfit for donation, of whom about 28 may not have been deceased when the donation process began.

HHS announces organ donation reforms after investigation (CNN, 2025)

HRSA ordered a corrective action plan and 12-month monitoring for the Kentucky-area OPO

HRSA / OPTN / Network for Hope (formerly Kentucky Organ Donor Affiliates)

HRSA's Division of Transplantation issued its investigative report on the Kentucky-area OPO (formerly Kentucky Organ Donor Affiliates, now Network for Hope) on March 24, 2025, and on May 28, 2025 issued a Corrective Action Plan directing OPTN to develop a 12-month monitoring plan and to propose public-comment policies improving safeguards for potential donation-after-circulatory-death patients and increasing information shared with families.

OPO Corrective Action Plan and OPTN Directive, May 28, 2025 (OPTN/HRSA)

HRSA ordered an OPO case reopened over potentially preventable harm and mandated corrective actions

Kentucky Organ Donor Affiliates (now Network for Hope)

According to a 2025 HHS announcement, HRSA directed the Organ Procurement and Transplantation Network to reopen a case involving potentially preventable harm to a neurologically injured patient by the federally funded OPO serving Kentucky, southwest Ohio, and part of West Virginia, and mandated corrective actions including a root-cause analysis of noncompliance with the five-minute observation rule after declared death, enforceable donor-eligibility criteria, and a formal procedure allowing any staff member to halt a donation if patient-safety concerns arise.

HHS: HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System

Kentucky OPO whistleblower removed from operating rooms days after congressional testimony; CEO denies retaliation

Kentucky Organ Donor Affiliates (Network for Hope)

A former surgical preservation coordinator at Kentucky Organ Donor Affiliates (KODA, since merged into Network for Hope) testified to Congress about organ-recovery safety concerns and said she was told two days after a congressional hearing that the OPO no longer wanted her in operating rooms. At the December 2, 2025 House Ways and Means Oversight Subcommittee hearing, Rep. Erin Houchin (R-Ind.) stated the public 'would not necessarily know about the depths that this has gone at KODA were it not for that whistleblower who was subsequently fired by a procurement agency.' Network for Hope's CEO publicly denied that the action was retaliatory.

WDRB Investigates: Kentucky woman says she was fired after raising concerns about an organ donation case

An OPO described using for-profit organizations to place 'research' organs to satisfy CMS metrics

Kentucky Organ Donor Affiliates (KYDA) (primary-source letter reproduced in Senate Finance report)

A KYDA response letter reproduced verbatim in the Senate Finance 'Operation Transplant' report states that, following a 2012 CMS recertification corrective-action plan, KYDA increased the number of national research organs recovered 'by utilizing for-profit organizations to place organs for research (which requires approval by KYDA's Board of Directors).' The report separately documents that surveyed OPOs reported an 850% increase in pancreata recovered for research without a clearly corresponding research benefit.

Operation Transplant Staff Report — Senate Finance Committee (KYDA letter reproduced therein)

Network for Hope (formerly Kentucky Organ Donor Affiliates) drew federal investigation and corrective action (2024-2025)

Network for Hope / Kentucky Organ Donor Affiliates (KODA)

A federal HRSA investigation reviewed more than 350 organ-procurement cases handled by Kentucky Organ Donor Affiliates (since merged into Network for Hope) and found about 70 patients had neurological conditions making them unfit for donation, of whom 28 may not have been deceased when the donation process began. The findings prompted congressional scrutiny and a broader HHS-announced organ-donor safety overhaul in July 2025.

CNN — HHS to begin reforms of organ donation system after federal investigation

HRSA investigation found organ-procurement initiation on patients with concerning features in DCD cases

Health Resources and Services Administration (HRSA) / OPTN; Network for Hope (formerly Kentucky Organ Donor Affiliates, KYDA)

A HRSA Division of Transplantation report (March 24, 2025) on the OPO serving Kentucky and parts of nearby states reviewed 351 cases and found 103 (29.3 percent) showed concerning features in the donation-after-circulatory-death (DCD) process, including problems with neurological assessment and recognition of signs the agency described as raising safety concerns. HRSA issued a corrective action plan directing the OPTN to strengthen DCD safeguards.

Strengthening Organ Donation and Procurement Safety (HRSA)

HRSA found nearly 30% of reviewed Kentucky-OPO circulatory-death cases had concerning features, with some patients possibly not deceased when organ recovery was initiated

Health Resources and Services Administration (HRSA); Organ Procurement and Transplantation Network (OPTN); Kentucky-area OPO (formerly Kentucky Organ Donor Affiliates, now Network for Hope)

HRSA's Division of Transplantation reviewed 351 authorized-but-not-recovered cases at the Kentucky-area OPO and found 103 (29.3%) had 'concerning features,' including poor neurologic assessments, weak coordination with hospital teams, and questionable consent. HRSA reported that at least 28 patients may not have been deceased at the time organ procurement was initiated. HHS issued a corrective-action plan (dated May 28, 2025) and an OPTN directive in response.

HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System (HHS.gov, 2025)

HHS/HRSA investigation found organ-recovery procedures initiated on patients who showed signs of life

Health Resources and Services Administration (HRSA); OPTN; Network for Hope (formerly Kentucky Organ Donor Affiliates)

HHS announced in July 2025 that an HRSA investigation of an organ procurement organization (Kentucky Organ Donor Affiliates, now Network for Hope) reviewed 351 authorized-but-not-completed donation cases and found 103 (about 29 percent) with concerning features, including 73 patients with neurological signs incompatible with donation and at least 28 patients who may not have been deceased when organ-procurement processes were initiated. HRSA mandated corrective actions and directed OPTN to strengthen national safeguards and reporting of safety-related stoppages.

HHS.gov, "HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System" (July 2025)

HRSA mandated corrective actions tied to the five-minute observation rule and staff authority to halt donation

Kentucky Organ Donor Affiliates / HRSA, HHS

As part of the July 2025 action, HRSA directed corrective actions for the organ procurement organization formerly operating as Kentucky Organ Donor Affiliates (since merged and operating as Network for Hope), including a root-cause analysis of noncompliance with the five-minute observation period following declaration of circulatory death and adoption of a formal procedure allowing any staff member to halt a donation process when patient-safety concerns arise.

HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System (HHS.gov, July 21, 2025)

HRSA-directed review centered on the OPO serving Kentucky and adjacent areas (formerly Kentucky Organ Donor Affiliates, now Network for Hope)

Kentucky Organ Donor Affiliates / Network for Hope (organ procurement organization)

A federal review found that staff at the OPO serving Kentucky (formerly Kentucky Organ Donor Affiliates, now operating as Network for Hope) pursued donation procedures in cases where patients showed signs of life, improperly took over case management from physicians, and pressured families to proceed. The OPO was directed to conduct a root-cause analysis, including of noncompliance with the post-death observation period, and to develop enforceable donor-eligibility policies. Stated at the institution/finding level; no patient-identifying detail included.

Ky. nonprofit pushed for organ donation procedures despite signs of life, federal investigation finds (WKYT)

HRSA review found concerning features in ~29% of authorized-but-not-completed donation cases at one OPO

Health Resources and Services Administration (HRSA), HHS / Kentucky Organ Donor Affiliates (KODA)

A HRSA investigation reviewed 351 cases at one organ procurement organization in which donation after circulatory death (DCD) had been authorized but was not completed. The review identified 103 cases (29.3%) with concerning features, including 73 patients with neurological status reported as incompatible with donation. The review concluded that at least 28 patients may not have been deceased at the time the organ procurement process was initiated, and cited poor neurologic assessment, weak coordination with treating clinical teams, and questionable consent practices.

HHS Finds Systemic Disregard for Sanctity of Life in Organ Transplant System (HHS.gov)

Four-year HRSA investigation of a Kentucky OPO (now Network for Hope, formerly Kentucky Organ Donor Affiliates) led to a federally directed corrective action plan

Network for Hope (formerly Kentucky Organ Donor Affiliates / KYDA)

HRSA's Division of Transplantation issued a March 24, 2025 report summarizing an investigation into the OPO then known as Kentucky Organ Donor Affiliates (now Network for Hope), which serves Kentucky and parts of neighboring states. On May 28, 2025, HRSA issued a Corrective Action Plan directing the OPTN to take specified actions, including a 12-month monitoring plan for the OPO. HRSA stated that after this review it had received reports of similar high-risk donation-after-circulatory-death procurement patterns at other OPOs.

Strengthening Organ Donation and Procurement Safety (HRSA)