Why It Matters

The Association of Organ Procurement Organizations faces sweeping organ transplant system reforms following federal investigations revealing safety violations and financial conflicts of interest.

There were three major 2025 congressional hearings scrutinizing OPO accountability and multiple reform bills addressing donor referrals. The stakes are enormous: declining organ transplants and eroding public trust make legislative outcomes on performance metrics and federal oversight critical to the organization’s regulatory future.

By the Numbers

AOPO’s $80,000 quarterly lobbying engagement with Holland & Knight LLP shows its deep pockets. It has filed 96 disclosures since 2003 and spending $4.36 million total on federal lobbying.

The organization has dramatically shifted strategy, moving from external firms to investing heavily in in-house lobbying capacity—now its largest expenditure at $1.915 million over 20 disclosures—while retaining Holland & Knight for $1.24 million across 21 disclosures.

Holland & Knight deployed four registered lobbyists for AOPO, including Sarah Elizabeth Starling Crosson, who served on the Senate HELP Committee—the very panel investigating organ procurement reform—and Jordan K. Brossi, former health policy adviser to Rep. Anna Eshoo (D-CA) on House Energy and Commerce.

The Agenda

AOPO lobbied on four specific issues: Medicare organ procurement organization regulations, organ donor referral bills, FAA rules governing organ transportation, and general organ procurement education.

This occurs amid intense congressional scrutiny. The House Ways and Means Committee examined tax-exempt OPO practices in December, House Energy and Commerce held oversight hearings in July, and the Senate HELP Committee examined the organ procurement network’s future in November.

AOPO officially endorses the Organ Donation Referral Improvement Act (H.R. 330), which directs HHS to study automated referral systems.

Broader Context

Congress has placed unprecedented scrutiny on organ procurement in 2025, driven by damaging federal investigations. The HHS Inspector General revealed concerning features in 103 cases, with at least 28 patients potentially not deceased when organ procurement began. A bipartisan Senate Finance Committee report exposed how OPOs inflated performance metrics through a "pancreata loophole", increasing research collections over 400 percent since 2020.

Whistleblower allegations documented widespread corruption, including organ diversion based on socioeconomic status. Meanwhile, the U.S. is experiencing declining kidney transplants, with over 100,000 Americans on waiting lists.

Between The Lines

Chairman Brett Guthrie (R-KY) has made OPO reform a personal priority, signaling strong bipartisan momentum. AOPO’s endorsement of reform legislation suggests positioning itself as reform-minded while protecting operational flexibility.

Competitive Landscape

The advocacy space is crowded as reform efforts intensify. UNOS spent $120,000 in the first half of 2025 lobbying on organ donation issues, while Indiana Donor Network retained its own lobbying firm. This multi-level strategy reflects high stakes as Congress weighs significant reforms.

The Bottom Line

AOPO is ramping up federal advocacy amid intense congressional scrutiny, spending $80,000 in the last quarter with Holland & Knight while maintaining substantial in-house lobbying efforts totaling $1.9 million since 2021. The organization’s lobbying team includes former staffers from the very committees leading reform efforts, reflecting the industry’s urgent need to shape outcomes on performance metrics, oversight authority, and accountability mechanisms.

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