The Health Resources and Services Administration reviewed 351 cases from 2021 through 2024 in which organ donation was authorized but not completed. The organ procurement group did not respond to additional questions about the basis of its appeal, its current operating status and contingency planning with hospital partners. The current investigation stems partly from a 2021 case involving Network for Hope’s predecessor, Kentucky Organ Donor Affiliates. Organ procurement organizations do not declare patients dead; that determination is made by physicians at the treating hospital. HHS broadened its investigation into Network for Hope in 2025, concluding that at least 28 patients may not have been deceased when the organ procurement process was initiated.