# OIG Recommends CMS Revise Organ Cost Reporting

The Office of Inspector General (OIG) identified nearly $380 million in improper Medicare payments to certified transplant centers due to conflicting guidance from the Centers for Medicare & Medicaid Services (CMS) and federal regulations on organ acquisition cost reporting. The OIG recommends that CMS update its guidance to require transplant centers to report only organs transplanted into Medicare enrollees for reimbursement purposes. CMS has acknowledged the findings and is reviewing alternative methodologies and public comments to align its regulations and guidance accordingly.

- This development signals potential changes in Medicare cost reporting requirements for transplant centers, impacting reimbursement processes and compliance obligations.
- Procurement professionals and contractors supporting transplant centers or Medicare Administrative Contractors (MACs) should prepare for revised reporting standards that may affect billing and audit procedures.
- Organizations involved in Medicare payment processing and compliance should evaluate current practices against forthcoming CMS guidance updates to mitigate risks of improper payments.
- CMS's ongoing review indicates that regulatory alignment efforts may lead to updated rules or policies affecting organ acquisition cost calculations in the near term.

**Jurisdictions:** federal
**Industries:** Healthcare
**Topics:** Regulatory Compliance
**Published:** September 18, 2026

### Government Entities
- Office of Inspector General (OIG)
- Centers for Medicare & Medicaid Services (CMS)
- Medicare Administrative Contractors (MACs)

### Key Quotes
> CMS did not concur or nonconcur, and instead (a) referred to its proposed rule that it had requested information on alternative methodologies for counting organs for purposes of calculating Medicare’s share of organ acquisition costs; (b) stated that it was reviewing comments in response to that proposed rule and would continue exploring alternate options; and (c) stated it would consider the OIG’s findings and recommendations while determining next steps, and update its guidance to ensure regulatory alignment.
> — Centers for Medicare & Medicaid Services Response

### Sources
- [ORGAN PROCUREMENT AND... | VitalLaw.com](https://www.vitallaw.com/news/organ-procurement-and-transplantation-oig-reports-conflicting-cms-guidance-federal-regulations-cause-nearly-380m-in-improper-payments-to-organ-transplant-centers/hld01653f3957f8904e089eba8e4e26cf5753) - VitalLaw.com