HHS Begins Decertification of Network for Hope, Kentucky’s Organ Procurement Organization

On August 5, 2026, the U.S. Department of Health and Human Services (“HHS”) announced that the Centers for Medicare & Medicaid Services (“CMS”) has begun the decertification process for Network for Hope, the organ procurement organization (“OPO”) with a service area that includes Kentucky and portions of Indiana, Ohio and West Virginia. According to HHS, the action follows multiple federal reviews that identified ongoing patient safety concerns and determined that the OPO had not demonstrated sufficient improvement despite corrective action efforts and federal oversight.

Potential Impact on Hospitals and Other Stakeholders

While HHS’s announcement focuses on the decertification process itself, hospitals, including transplant centers and donor hospitals, and other organizations that interact with Network for Hope will likely have operational, compliance and patient care questions as the process unfolds. HHS has not yet provided detailed information regarding transition plans, replacement OPO coverage or implementation timelines. Stakeholders in Kentucky and the affected portions of Indiana, Ohio and West Virginia should continue monitoring developments and evaluate whether existing policies, procedures, agreements and communication pathways may be affected by future federal actions.

The announcement is also part of broader federal efforts to increase oversight and accountability within the organ procurement and transplantation system, including heightened scrutiny of patient safety, OPO performance and regulatory compliance.

Practical Takeaways

• Network for Hope has stated that it intends to appeal HHS’s decertification decision. While the appeal and transition processes move forward, impacted stakeholders should continue business as usual in complying with all existing donor referral, reporting and operational requirements.
• Hospitals, including transplant centers, and other providers served by Network for Hope should closely monitor additional guidance from HHS, CMS and HRSA regarding the decertification process.
• Organizations should evaluate whether any internal policies, procedures, agreements or operational workflows depend on the OPO’s current service area designation.
• Stakeholders may wish to assess contingency planning and communication protocols as additional information becomes available regarding future OPO coverage and transition requirements.
• Providers should remain attentive to broader federal initiatives involving OPO oversight, patient safety and organ procurement system reform.

If you have questions regarding the potential impact of this development on your organization or would like assistance evaluating operational, regulatory or compliance considerations, please contact:

• Lori Wink at (414) 721-0456 or lwink@hallrender.com;
• Megan Culp at (317) 429-3644 or mculp@hallrender.com;
• Hall Render’s Transplant & Organ Procurement service line; or
• Your primary Hall Render contact.

Special thanks to Summer Associate Nick Baker for his assistance in the preparation of this article.