The invoice follow-through supplied the larger share
The federal kidney-transport audit identified $188,147 in unallowable sampled costs and another $240,178 outside the initial sample. What’s the Scoop With Broach calculated that the additional review produced 56.1% of the $428,325 total. The larger part of the finding came from following invoice entries and ledger descriptions beyond the initially selected transactions.
The audit covered 43 independent organ procurement organizations. Investigators selected 213 high-dollar transportation costs totaling $3,670,675 and examined other entries appearing on invoices or described as potentially unallowable. The sample was nonstatistical, so neither its transaction failure rate nor its dollar findings should be projected across every organ journey.
The two organization counts also overlap: 21 had sampled problems and 26 had additional problems, with 15 in both groups. The reconciled total is 32 organizations. Adding 21 and 26 would overstate the number involved by 15.
| Finding category | Amount | Share of total, calculated |
|---|---|---|
| Misallocated costs for other organs:$128,747 + $143,993 | $272,740 | 63.7% |
| Funeral-service transportation | $96,185 | 22.5% |
| Inadequately supported costs | $59,400 | 13.9% |
| All findings | $428,325 | 100%; rounding affects sum |
| From additional review | $240,178 | 56.1% |
Money classification and transport safety require different proof
A payment can be classified incorrectly even when an organ arrives safely. Conversely, a properly classified invoice does not establish that every safety check occurred. The audit’s cost findings and its four transport-compliance findings answer separate questions.
Current federal rules require two people, including an OPO employee, to verify accompanying documentation and label information. They also require complete donor documentation, specified paper records and written protocols covering packaging, labeling, handling and shipping. The rule’s purpose is to ensure arrival without compromising organ quality.
OIG found three cases without support for the required two-person verification and one without electronically supplied consent documentation. It did not identify a safety-related mislabeled-organ incident in its sample. The evidence supports a compliance gap; it does not establish that the sampled failures injured a recipient.
The response promises recovery and education, not completed collection
OPOs attributed the accounting problems to clerical errors and, for funeral transportation, misunderstanding reimbursement rules. CMS agreed to direct recovery through cost-report adjustments and additional education. Those commitments do not establish that every dollar had already been collected when the report was released September 23.
Our original contribution is the reconstruction of where the finding came from and how its categories relate. It identifies the value of reviewing linked entries while keeping the total distinct from a statistically estimated industry loss. The 32 organizations are the audited organizations with identified costs; 74.4% of the 43 reviewed is a sample descriptor, not a nationwide error rate.
The cost schedules concern fiscal 2023 reports and were initially submitted before contractor settlement review. This is an examination of those public audit records and the transport rule, not an observation of a transplant flight or an independent review of patient charts.
Sources and further reading
HHS-OIG A-09-24-03009 full audit, Sep 23, 2026; printed pp 4–10 and Appendix A ↗
42 CFR 486.346, current eCFR through Oct 8, 2026 ↗