The tax-exempt status of New Jersey’s sanctioned organ procurement organization is under threat over allegations that its president and CEO attempted to strong-arm a hospital into harvesting organs from a patient that still showed signs of life, according to a House committee probing OPOs nationally.
The New Jersey Sharing Network is under investigation by the House Ways and Means Committee over concerns about potential “violations of federal and state statutes that raise serious concerns about whether NJTO fraudulently billed Medicare.” Also being investigated are allegations of other “egregious actions,” including fraudulent research, manipulation of documents and out-of-sequence organ allocations, according to a letter the committee sent to Carolyn Welsh, the president and CEO of the network.
The letter makes it clear that Welsh and her senior leadership team at NJ Sharing Network, which the committee refers to as NJTO in its letter, are the focus of the investigation. The letter specifically cites cases in which Welsh and her team allegedly skirted reporting rules, aggressively pushed for organ procurement in cases where donor status was unclear and covered up paperwork in a case where Welsh is alleged to have personally pushed for the harvesting of organs of a patient who had “reanimated.”
The committee also alleges that a “culture of fear and retaliation” was fostered by Welsh and her leadership team.
The NJ Sharing Network did not immediately respond to The FORUM’s request for comment.
The 23-page letter to the NJ Sharing Network comes after the committee in July 2025 sought information from the network concerning Medicare reimbursements and its organ procurement and research practices. The network informed staff in July that it was cooperating with the committee. But whistleblowers continued to contact the committee, revealing the failed organ-harvesting case, the letter states.
In that case, a patient in Virtua Our Lady of Lourdes Hospital in Camden was referred to the network for possible organ donation. The patient was taken off life support, pronounced dead and scheduled for organ recovery. Soon after, however, the patient showed signs of life, and the hospital called the network for advice. Welsh told them to proceed, but the hospital intervened and the organ harvesting was called off, the letter alleges.
“It is the committee’s understanding not only that the NJTO staff on site continued to pressure the hospital staff to proceed with the donation, but also that you were the individual who made the decision to continue with the process of donation with knowledge of the donor’s reanimation,” the letter said of Welsh. “The committee further understands that you–someone with no clinical training–decided to proceed from outside of the hospital, even while the hospital staff on site shared concerns about your decision.”
The letter also alleges that the documentation concerning the case was manipulated and tampered with.
While the Lourdes case was the most sensational mentioned in the letter, the committee also detailed what it says was a systematic and aggressive effort to bump up the numbers of procurements and transplants, ignoring well-established regulations governing the process.
The letter alleges that the network used a “Document of Gift,” through a partnership with the New Jersey Motor Vehicle Commission, in which all information except a person’s name and gender was redacted and no donor status was indicated. That document was used to tell donor families that the network had the decedent’s irrevocable consent to harvest organs even if the person’s driver’s license did not indicate the decedent was a donor, the letter continues.
“If true, not only is this aggressive behavior a potential violation of state law, it also breaks trust in the organ transplant system, which is vital to maintaining crucial life-saving services,” the letter states.
The committee also alleges that the network engaged in an aggressive effort to circumvent the order of allocation for organ donation, which is used to determine the most in-need potential recipients. Part of that effort was using an offline system of unrecorded calls and improper documentation, “brazenly ignoring” protocol.
“There is also a question as to NJTO’s purpose in departing from the proper allocation sequence, considering there is no cognizable benefit to skipping over transplant waitlist patients,” the letter stated. “The committee is concerned that NJTO could be seeking to ensure higher metrics for certification and tiering standards or ensuring as many organs as possible can be listed on your Medicare Cost Reports.”
The network has touted the success of its organ procurement over the past several years, posting yearly records in the numbers of donations and transplants.
The committee also said the network had not provided it with all the information the committee had been requesting since it first began looking into alleged issues with OPOs in early 2025. Information provided was “either incorrect or incomplete,” specifically regarding pancreatic research on organs that were discarded en masse.
“The committee is aware that NJTO is in possession of information that it has not produced,” the letter stated, including an electronic folder of data that was created but never turned over.
The committee based the allegations in its letter on “nearly a dozen whistleblowers and documents including communications, audio files and databases,” saying that the network “potentially violated a number state and federal laws.”
The committee concluded its letter with a reminder of the network’s obligations under the law and of the potential consequences of noncompliance. It is demanding interviews with more than 30 network employees and board members, including Welsh.
“Government oversight of highly regulated medical industries, like your own, is critical to ensuring donor and recipient safety,” the letter states. “Failure to comply with these requests will result in the issuance of subpoenas.”
The network has until December 3, 2025 to respond. Copies of the letter were sent to U.S. Department of Health and Human Services Secretary Robert F. Kennedy Jr., network Board of Trustees Chair Dr. Patrick Buddle, network Advisory Board Chair Dr. John Radomski and New Jersey Attorney General Matthew J. Platkin.