GAO Recommends Reforms to Organ Transplantation Oversight

On Thursday, January 22, 2026, the U.S. Government Accountability Office (GAO) released a report containing three main recommendations for improving the oversight and operations of the Organ Procurement Transplant Network (OPTN), a public-private partnership composed of Organ Procurement Organizations (OPOs) and hospital programs providing transplantation services. Specifically, the GAO recommends that HHS and the Health Resources and Services Administration (HRSA) (1) make a detailed plan for what steps are needed in the OPTN Modernization Initiative, (2) improve the transparency in what OPTN contractor fees are optional as opposed to mandatory, and (3) set firmer and more specific milestones for tracking providers’ effectiveness.

HRSA’s OPTN Modernization Initiative

Despite over 41,119 organ transplants occurring from deceased donors in 2024, there remains a nationwide shortage of organs and over 100,000 patients remain on the national organ transplant waiting list. To address the national shortage and concerns expressed by Congress, academics, and the press, HRSA launched the OPTN Modernization Initiative in March 2023. One of the first steps that HRSA implemented as part of the initiative was executing contracts to study seven areas of potential weaknesses:

1. Organ Matching IT System: Improving the OPTN’s system for matching donors and patients and addressing potential data security issues in the system.
2. Policy Development: Shortening the amount of time it takes OPTN to develop and implement new policies.
3. Organ Transportation: Improving the tracking of organs and addressing logistical challenges.
4. Organ Allocation: Ensuring that the distribution of organs is “equitable, consistent, and transparent[.]”
5. OPTN Oversight of Members and Patient Safety: Setting performance metrics for OPOs and transplant hospital and investigating patient safety concerns.
6. Communications: Improving transparency, such as keeping patients on the waiting list abreast of “when transplant programs decline organs on their behalf,” and sharing patient safety issues with both patients and their families.
7. Financial Management of OPTN Operations: Improving transparency in the process used to set the OPTN registration fee, a charge that transplant programs need to pay each month for each patient they add to the national waiting list.

In December 2025, HRSA reported that it had received the results of these studies but was still working on how to best address these issues.

The GAO’s Evaluation of the OPTN Modernization Initiative

In its January 2026 report, the GAO evaluated the effectiveness of HRSA’s OPTN Modernization Initiative by analyzing HRSA’s reports between 2019 and 2025, interviewing HRSA officials, and interviewing HRSA stakeholders such as OPOs, transplant hospitals, transplant surgeons, and transplant patients. Though the GAO lauded HRSA’s OPTN Modernization Initiative for its effort to study potential weaknesses, the GAO identified three actions that it believes are necessary to move the initiative forward:

1. Creating a Detailed Plan for Addressing the Identified Weaknesses: Though the GAO indicated that it was broadly happy with the contracts that HRSA entered to study issues with the organ transplantation system, the GAO also indicated that it believes HRSA’s plans for addressing these issues need a greater level of detail.
2. Studying Risks Related to Services that OPTN Contractors Charge: The GAO indicated that it did not believe HRSA did enough to study the lack of transparency in the charges that OPTN members pay to OPTN contractors. Specifically, the GAO is concerned that OPTN contractors may be vague in communicating what fees are required and which fees are for optional, supplemental services.
3. Setting Specific and Actionable Milestones for Measuring Success: The GAO indicated that HRSA’s Organ Transplant Affinity Group (OTAG) should create an action plan that “includes specific, actional steps with milestone completion dates and markers for measuring success[.]”

The GAO’s report, highlights, and recommendations can be found here.