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So is the lettuce bad or not?

A green head of lettuce, in close-up.

What caused the ongoing outbreak of cyclospora, the diarrhea-causing parasite currently spreading across the United States? Michigan officials have been saying for weeks that they believed the outbreak may be linked to bagged salad or salad kits. What we were waiting to learn was the specific brands and specific products in question. 

And late last week, it looked like we finally had the answer — but then things quickly got cloudy. 

On July 16, the Washington Post reported, citing anonymous sources, that the outbreak had been linked to shredded iceberg lettuce supplied to Taco Bell by Taylor Farms. A day later, Taylor Farms said it was withdrawing products from US stores and restaurants based on information from the FDA.

But then on July 19, per NBC News, the FDA said that there had been a false positive for cyclospora when testing a sample of Taylor Farms iceberg lettuce; Taylor Farms said in its own statement that the FDA had “apologized” for the mix-up. The next day, the company and the federal government were stuck in a semantic argument: Per NOTUS, the FDA insisted it did not “officially apologize” to Taylor Farms but “explain[ed] factually the issues” with the false positive. 

So where does that leave us right now? Officials still believe that Taylor Farms iceberg lettuce was the source of the Michigan outbreak. But whether those are the only products driving the outbreak remains unclear, with almost every state now reporting at least one cyclospora case in 2026. And on Thursday afternoon, the FDA announced that it was tracking a second outbreak linked to other unspecific products, though details were otherwise scarce.

Any outbreak of food-borne illness requires careful public communication. Officials need to tell people how to avoid contaminated food without scaring them away from eating fresh fruits and vegetables altogether.

But instead, many Americans have been left wondering what, exactly, they’re supposed to do. As one frustrated Reddit user put it: “So is the damn lettuce bad or not????” (If you need some advice on what foods are safe and what foods to be cautious about, we have a story for you.)

It may sound like a funny question, but it’s a profoundly serious one. The problem isn’t just that people are confused about their lettuce. The Trump administration’s handling of the cyclospora outbreak — from its conflicting public messages to accusations of political favoritism — has left many Americans even more confused about whether they can trust anything they’re hearing from the government. That’s a dangerous place to be during any public health emergency.

The cyclospora outbreak has become a communications nightmare

We are approaching 10,000 cyclosporiasis cases across the US this year: Michigan alone has recorded 7,664 as of this morning, Ohio has seen more than 1,200, and more than 40 states have now reported at least one case in 2026. The country usually sees a few hundred cases at most in a given year. Cyclosporiasis, the disease caused by the cyclospora parasite, leads to what public health experts describe as “watery” and “frequently explosive” diarrhea. While it isn’t typically life-threatening, it can cause serious complications: 160 people have been hospitalized in Michigan since the outbreak began.

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And so for those of us who very much hope to eat fresh produce but do not want diarrhea, there’s a bit of urgency to figure out where the cyclospora is coming from. Food-borne illness investigations are already inherently difficult because of how globalized our food supply has become: Produce can travel all over the country and the world before it comes to your grocery shelf, and the process of government health workers interviewing the people who get sick and cross-checking to identify the shared foods that they might have in common is laborious.

Once investigators find a source, the information has to be shared clearly and responsibly. That is where the Trump administration has tripped up this week. 

Trump — and Health Secretary Robert F. Kennedy Jr. in particular — came into office criticizing the public health establishment. They accused officials of misleading the public about the novel coronavirus and the vaccines developed to fight it, while failing to convey the nuances of the pandemic. But now, as they grapple with the incomplete picture of the cyclospora emergency, they are making many of the same mistakes.

“They’re very similar problems, even if on the outside, they don’t look quite the same,” said Michael Mackert, director of the Center for Health Communication at the University of Texas at Austin. “The underlying commonality is very much that we are dealing with imperfect information all the time.”

In any outbreak, some uncertainty is to be expected. Investigators have struggled to identify the source of earlier cyclosporiasis outbreaks too. And the FDA maintains that the likely source of the outbreak is Taylor Farms iceberg lettuce, based on the information they have gathered from sick patients and other sources, no matter the false positive result that has sparked so much confusion.

“The epidemiological evidence is so strong that the lack of a positive test is almost meaningless,” said Francisco Diez-Gonzalez, director of the Center for Food Safety at the University of Georgia. 

But the mistake that the Trump administration made was in sharing preliminary results and then having to issue a seemingly contradictory statement shortly afterward.

“FDA should have waited for confirmation of the presumptive results before going public,” Diez-Gonzalez said.

The larger stakes of the Trump administration’s poor communication

Investigations like these are hard enough — but when you add in the public health funding cuts of the past 18 months and the casual and widespread corruption characteristic of the Trump administration, trust in the government’s public health apparatus has sunk even lower.

It’s created just the conditions for conspiracies to bloom. “Unfortunately our FDA is compromised,” wrote one top commenter on Reddit. “I would not trust what comes out of it during this administration.” 

Several news outlets and influential social media accounts noted that Taylor Farms had donated $1 million to Trump’s MAGA super PAC and, in the middle of the controversy, received a private White House meeting. According to the New York Times, Taylor Farm officials used that meeting to dispute the findings that their products were responsible for the outbreak — and shortly thereafter, the FDA made its “false positive” announcement.

The administration insists that their decision-making is being guided by science, but even the appearance of impropriety has become a common theme in the press coverage. The broader uncertainty and distrust may help to explain why it’s not only Taco Bell and Taylor Farms taking a hit right now: According to Market Watch, Chipotle and the fast-casual salad chain Chopt have also seen a decline in traffic in recent weeks.

Public health requires public confidence. Perceived influence from special interests is a problem, even if the interactions didn’t alter the FDA or CDC’s actions.

Kennedy, who helms our government’s health department, should understand this well: His Make America Healthy Again movement made restoring public trust a central part of its message while accusing the existing public health establishment as being in league with special interests. 

The cyclospora outbreak has revealed how difficult that is to do in practice. 

In trying to communicate nuanced information during an active outbreak — while consulting interested parties like Taylor Farms itself — the administration has instead fueled doubts about the credibility of its messaging

Even before cyclospora turned eating salad into a leap of faith, Trump had a poor track record: His administration has slashed CDC staff, brought on vaccine skeptics to set vaccine policy, and clashed with the scientific establishment on a number of high-profile issues, like the time Trump held a televised press conference to argue a disproven theory that Tylenol can cause autism.

“Unfortunately, this is another example of a missed opportunity to establish credible and trusted communications to prepare the public to understand the real risks from the pathogen and confidence in the food safety and information from the FDA,” Scott Ratzan, editor-in-chief of the Journal of Health Communication: International Perspectives, told me. “Faith in our institutions continues to erode. We could do better.”

We are lucky cyclospora is not a deadly disease. Next time, the stakes for these miscues could be much higher.

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The breakthrough changing how Americans donate organs

an illustration of one heart pouring blood into another
Instead of death being declared because the brain has stopped functioning, in DCD, death is declared after circulation ceases and the heart stops beating. | Miguel Porlan for Vox

This story was originally published in The Highlight. To get access to member-exclusive stories like this every month, become a Vox Member today.

Emily Hoffman was walking home from lunch in the Pittsburgh neighborhood of Squirrel Hill in February 2023, when a driver turning left struck her on the crosswalk.

Hoffman was 34. By the time paramedics arrived on the scene, she had gone into a traumatic cardiac arrest. They strapped her onto a machine that delivered automated chest compressions and rushed her to UPMC Presbyterian, a major trauma hospital in Pittsburgh.

Over the next several days, doctors performed multiple surgeries, kept Hoffman on a ventilator, and waited until she was stable enough for an MRI. The scans showed multiple strokes and severe traumatic brain injury. She was alive, but her family understood that she was not going to make a meaningful recovery to a life she would have wanted.

The next Thursday, a week after the crash, Emily’s parents and her sister Beth Hoffman met with the care team and decided to remove ventilator support to allow her to die naturally. Organ donation came up only afterward. Emily was already a registered donor, and Beth knew it was what her sister wanted.

For most of the short history of organ transplantation, Emily would not have been the usual kind of organ donor.

Almost all transplanted organs once came from patients who died in one specific and rare way called brain death, in which the brain has irreversibly stopped functioning, even as machines keep the heart beating and the organs supplied with oxygen. Brain death is extraordinarily rare,  but it happens often enough to create a workable — though far from sufficient — supply of life-saving organs.

But Emily was not one of the brain-death donors. Even after the strokes and brain injury, she still had some reflexes. She was dying, but not brain dead.

Her donation followed a different path, one that has transformed American transplantation in the last decade. It is called donation after circulatory death, or DCD. Instead of death being declared because the brain has stopped functioning, in DCD, death is declared after circulation ceases and the heart stops beating. Many more people die this way than by brain death.

Death by circulatory criteria has been legally recognized since the 1980s, but for decades, doctors rarely recovered organs this way, because, once blood stops moving through the body, organs begin to deteriorate within minutes. In recent years, however, new machines and surgical techniques have helped change that, giving doctors the ability to preserve organs outside the body, making DCD far more viable.

↗ Explore the interactive version of this chart.

Hoffman’s donation is hardly an outlier anymore. In the last decade, DCD has gone from a rare practice to something that now accounts for nearly half of all organ donors who have died in the United States. In 2000, DCD donors supplied just 219 organs (kidneys, livers, lungs, hearts, and pancreas combined) to the transplantation system in the US. In 2025, DCD brought in close to 17,000 organs. (Most transplanted organs, about 85 percent, come from dead donors, though some organs, most often kidneys, can also come from living donors.)

That growth has saved lives, but it has also pushed transplant medicine into an unusually sensitive moment: the time after a family has decided to let their loved one die but before death has actually occurred.

In brain-death donation, a patient has already been declared dead before the possibility of donation is raised with the family. Because most brain-dead donors are on ventilators, with machines supplying oxygenated blood to their organs, transplant teams can take their time with the donation process.

DCD doesn’t offer that same cushion. Because organs deteriorate so quickly after circulation ceases, the work of donation — the testing, matching, surgical teams flying in — has to be set in motion once the family has decided to withdraw life support but before the patient has died.

This is where the tension in DCD begins. The process pushes transplantation into the narrow interval between that decision to let someone die and the moment death occurs. It creates a situation with almost no parallel in medicine: one set of hands caring for the dying, even as another prepares to recover and transplant their organs.

The medical system tries to manage that complexity with a strict procedural sequence. First, hospital doctors and family conclude that no treatment will bring the patient back to a life they would have wanted. Only then, and only from a separate team, does the word donation come up. The firewall is in place so that the need for organs never shapes the decision to let someone die. 

“Ethically, you want to make sure that those two are uncoupled,” said Wade Smith, director of the Neurovascular Service at the University of California San Francisco.

But as DCD has scaled up, more weight is put on that narrow interval. What was once a rare event is now routine in hospitals across the country, carried out by teams with different levels of experience and overseen through rules that can vary from one place to another. At the same time, the organizations that handle organ donations are under new federal pressure to acquire and distribute more organs from eligible donors.

DCD has saved thousands of lives by making donations possible from patients who once wouldn’t have been donors. Hoffman’s donation improved several lives at once: Her kidneys went to two men, her liver to a third recipient, and her corneas helped give sight to a nine-month-old baby. 

But its growth has also made the fragile period before death more consequential: how families are told, which steps can be taken while the patient is still alive, how consistently hospitals and organ donation teams follow safeguards, and who has the authority to stop the process if something feels wrong.

When DCD was still rare, these questions stayed at the edges of transplantation. Now, they are moving towards its center, as a lifesaving practice becomes a routine part of how Americans die and donate.

Key takeaways

  • In the past decade, there’s been a boom in the number of organs available for transplantation in the US. 
  • Much of that growth has come from a little-known donation pathway called donation after circulatory death, or DCD.
  • DCD allows patients who are dying but not brain-dead to donate organs after their life support is withdrawn and their circulation stops. 
  • That boom has raised questions about medicine’s ability to manage the boundary between life and death.

The breakthrough

Modern transplantation is a relatively young field, only about 70 years old. And from the beginning, transplantation has depended on the novel medical achievement of keeping organs functional after a person had been declared dead.

The mechanical ventilator, developed in the 1950s, made that possible. It could keep a body breathing, and its heart beating, even after the brain had stopped for good. That created, for the first time, a situation where patients were deceased by every older measure, even as their organs were still functional.

Surgeons were initially wary of recovering organs, largely because the legal lines between life and death had never been clearly drawn. Then, in 1968, a Harvard committee proposed a definition of brain death. By 1981, a model law gave states the language to recognize two ways of legal death. Your heart and lungs could stop for good (circulatory death) or your entire brain could (brain death). Today, every state recognizes some version of that framework.

With those lines in place, transplant teams could work with more confidence, and brain death turned out to be close to ideal for them. Because a ventilator kept the heart beating and blood moving through the organs, even after death, there was no ticking clock to race against. The hospital staff had time to evaluate the organs, sometimes convince families to donate them, find the right recipients, and bring in surgical teams before recovery began.

The problem was always with the math. Brain death is rare — only about three in 1,000 deaths happen in a way that leaves organs usable for transplant. That puts a hard biological ceiling on how many ideal donors there could ever be.

But demand for the organs had no such ceiling. Nearly a million Americans are diagnosed with heart failure each year, while surgeons performed just 4,636 heart transplants in 2024, after DCD became a widely used part of transplantation, up 81.5 percent from 2013. There are “just not enough organs to go around,” said Ashish Shah, chief of cardiac surgery at Vanderbilt University. The kidney numbers are even bleaker. Over 500,000 people are on dialysis in the US, but only a fraction will ever reach the waiting list, and even among those who do, many will die before receiving a transplant offer, said Dorry Segev, a transplant surgeon and researcher at NYU Langone.

The modern DCD boom grew out of this desperation, presenting the possibility of donation in far more common cases of death that transplantation surgeons had rarely been able to draw on before: catastrophic strokes, car crashes, cardiac arrests, and other injuries that left patients with no meaningful chance of recovery but short of brain death. But with DCD, the clock suddenly became a factor. Once circulation stopped, the organs deteriorated fast, and, in many cases, they were ruined before surgeons could recover them. 

Because of those challenges, DCD stayed marginal for decades, at well under a tenth of all donations. Those numbers ultimately spiked because of several things that happened almost simultaneously.

One surprising thing

While reporting this story, I learned that the opioid crisis also expanded America’s supply of donated organs. Many people who died from overdoses in the US were young and otherwise healthy, making their organs suitable for transplant. It’s a grim reminder that transplantation lives in this space between one family’s — or community’s — catastrophe and another’s chance.

The first was technological. New machines, like TransMedics’ Organ Care Systems — which were first used in 2015 in the UK — could keep a recovered organ alive outside the body, pumping it with warm, oxygenated blood instead of packing it in ice, allowing a heart to beat and function as normal inside a box. This meant that even if there was delay in recovering an organ, that damage could be limited, even reversed, once the organ was put in the machine. 

Other teams found ways to use machines originally developed to support failing hearts and lungs to restart circulation inside the bodies of donors after death had been declared. Transplant teams in Spain and the UK began adapting that technology before American programs picked it up for DCD hearts around 2019. Both approaches helped extend the time to successfully perform DCD.

“As soon as the results were good, the big American centers took it on,” said John Dimarakis, a cardiac transplant surgeon at the University of Washington.

Policy changes also helped push DCD further. In Hoffman’s case, the donation process was coordinated by CORE, the nonprofit responsible for organ donation in the Pittsburgh region. Organ procurement organizations, or OPOs, cover a particular region in the US, and they work with hospitals in that region to evaluate potential donors, speak with families, arrange testing, and offer organs to transplant centers. There are 54 such OPOs in the US, which are certified and regulated by the Centers for Medicare and Medicaid Services (CMS). 

For years, critics argued that OPOs were judged according to weakly defined standards based on numbers they reported themselves, and poor performers were rarely penalized. But in 2020, new federal rules began ranking them against one another, with a mechanism to strip the worst performers of their territory. Facing the threat of losing their monopolies, many OPOs began pursuing harder cases they would’ve earlier passed over, according to Greg Segal, who founded patient advocacy group Organize. A larger share of those more complicated donors were DCD.

Still, no single force explains the speed of DCD’s rise. “Technology plays a big role in it,” said Nader Moazami, a cardiac surgeon at NYU Langone who helped pioneer one of the new techniques. “But it doesn’t explain how suddenly 50 percent of our donors are DCD.” In 2000, there were only 118 DCD donors in the United States. By 2025, there were 8,137. Brain death donation grew over that same period but far more slowly — from 5,867 donors a year to 8,416.

Line chart comparing annual US deceased organ donors by donation pathway from 2000 to 2025. Brain-death donors rose from 5,867 in 2000 to 8,416 in 2025, while circulatory-death donors rose from 118 to 8,137, nearly matching brain-death donors by 2025.

↗ Explore the interactive version of this chart.

Whatever the mix, it’s clear that DCD has led to more organs, shorter waits, and saved thousands of lives that otherwise would have ended on a list. “People who have been waiting now wait less,” Dimarakis said.

On a chart, it looks like an unambiguous triumph — until you step into a hospital room.

The passage

Beth Hoffman remembers her sister Emily’s last morning. She read aloud an email from Bradley Whitford, Emily’s favorite actor from the TV drama The West Wing, who had written after hearing what had happened. Then, a playlist of Emily’s favorite songs played as the breathing tube came out. Within about 10 minutes, while “For Good from Wicked filled the room, her sister was gone.

What Beth mostly didn’t see was the second sequence unfolding around her: the referrals, tests, calls, and scheduling that would turn Emily from a dying patient into an organ donor. 

Federal rules require every hospital to alert their organ procurement organization whenever a person may be nearing death. The OPO screens those referrals, and most go nowhere. Alexandra Glazier, who runs the OPO that covers most of New England, says hers get about 50,000 such referrals a year. Only 2 or 3 percent turn out to have any medical possibility of donation at all. 

Emily was one such possible case for her Pittsburgh hospital’s OPO. The organization had to reach out to her family; explain what DCD would involve; and, then, start the work that had to happen while she was still alive: reviewing her medical history, testing whether her organs could be used, matching them to recipients, and arranging the surgical teams who might fly in to recover them.

Most families never see much of that work, but some do. Smith, the UCSF neurologist, watched a family agree to withdraw life support and donate, set a time, and gather relatives for a final goodbye, only to learn that the withdrawal had to wait because the OPO still needed more tests. Some families, after being told their dying relative must stay on machines longer for donation’s sake, walk away.

For the Hoffmans, things proceeded more quietly. When the time came, Emily was wheeled into the operating room, and the breathing tube was removed there. The surgeons who would recover her organs were kept away from the withdrawal and death declaration. They often fly in from their own hospitals — sometimes several at once for different organs — but they’re walled off from everything that comes before. “We are not involved in that process,” said Dimarakis, the cardiac transplant surgeon at the University of Washington, “because it’s not ethical for us to be involved.”

That separation is the line DCD depends on. One team cares for the dying patient, withdraws support, and declares death. The other waits outside that decision and recovers the organs only after. The OPO stands between them, coordinating the donation without letting the firewall be breached.

Then comes the waiting. Once the ventilator is out, the clock starts ticking. If the heart doesn’t stop within a window — often about two hours — the organ recovery may be called off, and the patient is returned to end-of-life care. But when circulation does stop, as it did for Emily, the team counts exactly five more minutes to make sure it won’t restart on its own. Only then can a hospital physician declare death, and only then can the transplant surgeons begin.

DCD rests on a simple promise: The need for organs never causes the death. The death is already coming, and donation only changes what can come from it. 

But a new frontier in DCD complicates that promise.

The reversal

Normally, after death is declared, most DCD organs are removed and preserved outside the body, either on ice or on machines that circulate oxygenated fluid or blood. The goal is to slow the damage that begins the moment circulation stops.

A man’s hands hold an electronic medical device in the foreground while a robotic cart sits in the background

Then, around the mid-2010s, transplant teams in Spain and the UK began using a newer technique that restores circulation inside the dead donor’s body, before the organs are removed. It’s called normothermic regional perfusion, or NRP.

In one version of NRP, called abdominal NRP, blood is meant to be restored only below the diaphragm to preserve organs such as the kidneys and liver. In a more controversial version called thoracoabdominal NRP, it runs through the chest, as well, and the heart starts beating again.

For the transplant team, especially heart surgeons, the appeal is clear. Kidneys and livers can survive a stretch without circulation, but a heart is harder to preserve. Once it has stopped, there’s no easy way to know whether it will beat reliably again. NRP helps answer that question by restarting it inside the donor’s body after death has been declared, where surgeons can watch it work before deciding whether to recover it.

Shah, the Vanderbilt cardiac surgeon, says the technique lets doctors take hearts from donors who otherwise would not be able to yield a workable one.

But this kind of NRP is unsettling for the very reason that it is useful. If a death is declared because the heart has stopped, what does it mean to start it again inside a donor’s body, often only minutes later? Is that still death? Or something else?

The controversy isn’t simply that the heart beats again. A beating heart is not, by itself, the same as a living person. The heart of a brain-dead patient can beat, too, can be kept going by machines, and that doesn’t mean the person is alive. The deeper concern is whether restored circulation in the body could reach the brain, which could potentially restore consciousness.

To prevent blood from reaching the brain, surgeons clamp or cut the vessels that carry blood to the head before circulation is restored. That distinction is central to the defense of NRP, and it lets surgeons say they are restoring circulation and restarting the heart, not the person. 

But those safeguards haven’t always worked. In a safety notice last November, the Organ Procurement & Transplantation Network (OPTN), the federal system that oversees transplant policy and data, said it had received “verified reports” that blood had unintentionally reached the brain and brainstem during NRP. Such events are extremely rare, the notice said, but can occur when a clamp fails or blood reaches the head through an unrecognized route. The notice asked transplant programs using either form of NRP to strengthen their safeguards and report any failures. But those recommendations were not national requirements and as of May 2026, the OPTN was still developing formal standards for NRP. For Claire Morgan, a transplant surgeon from North Carolina who has criticized NRP’s rollout, that is a central weakness. “It’s a bulletin. It’s not a policy,” she said. “There’s no punishment for not reporting.”

But even if blood never reaches the brain, NRP can still introduce deeper ambiguity into our understanding of circulatory death. In the first few minutes after a heart stops, it can often be brought back, an event that happens every day in a busy emergency department. In conventional DCD, however, doctors don’t try to restart the heart, because a patient or family has already decided against being revived. It is that decision, not just the stopped heart itself, that turns the moment into a death. The same goes for anyone who dies under a do-not-resuscitate order.

NRP puts pressure on that logic. The circulation declared permanently gone is deliberately brought back. “There’s a misalignment between NRP practices and the legal standard for how death is defined,” said Glazier. You cannot, critics argue, pronounce someone dead because the circulation will never return — and then return it.

Robert Truog, professor of Medical Ethics, Anaesthesia, & Pediatrics at Harvard Medical School, supports NRP but thinks the possibility of blood returning to the brain is the issue that matters most. “The only questions are, is there a risk of pain or suffering in the procurement of the organs?” he said. And there’s a possibility of that if the circulation is restarted in the brain.

None of this is settled, which is why some hospitals refuse to perform NRP at all. Moazami pioneered the NRP heart technique in the US and practices it at NYU Langone. “But you cannot do it at Columbia,” he said, “just five miles away.” Glazier’s OPO, one of the country’s largest, said her organization has done roughly 650 NRP cases since adopting the practice — but only the abdominal kind, holding off on the heart version until the national protocols are better standardized.

Claire Morgan, a transplant surgeon from North Carolina who has criticized the rollout of NRP, is more worried about what happens if something goes wrong. The donor cannot complain, families may never know if there was a concern, and clinicians who speak up may have limited protection if they challenge what happened in the operating room. 

All of that matters, because NRP is already far from marginal. The Organ Procurement & Transplantation Network (OPTN), the federal system that oversees transplant policy and data, only began collecting data on whether NRP was used in a DCD recovery in October 2025. In the first five months of that reporting, from October 1, 2025, through February 28, 2026, 3,463 DCD donors were recovered nationally, according to data shared by the OPTN with Vox. More than half of those involved NRP; though, OPTN doesn’t collect data on which kind.

Vox’s analysis also found that NRP cases were concentrated among some organ procurement organizations. The top 10 OPOs accounted for 47 percent of all DCD recoveries that used NRP.

The patchwork

The core safeguard in DCD — that the decision to withdraw life support must come before questions about donation — is widely accepted. But many of the details around that sequence that shape a family’s experience, or a patient’s protection, are still handled differently from hospital to hospital, OPO to OPO.

“The entire process of DCD or donor withdrawal is not very standardized across the United States or even within states, even within different hospitals in the same city,” Moazami said.

That can mean differences in what families are told about the donation process, what medications are considered appropriate before death, whether NRP is allowed and how it is performed, and who has the clear authority to pause or stop the process if someone believes something is wrong.

That unevenness matters more now, because the transplant system has been trying, with good reason, to recover more organs. For years, many in the field, and those who depended on it, argued that the organ procurement organizations were leaving transplantable organs on the table. Greg Segal, whose advocacy group Organize helped push for stronger OPO accountability, compared the old system to a canvassing campaign where you only knock on the easiest doors. “The problem with OPOs is they were only doing the much easier ones,” he said.

A 2020 rule from the Centers for Medicare & Medicaid Services, the federal agency that oversees OPOs, was meant to change that. It ranked OPOs against one another and created a path to penalize low performers by stripping them of their territories. That policy appears to have had some impact, but it is hard to separate from other forces driving DCD’s rise including new preservation technology, like NRP and broader clinical adoption. Jeffrey Trageser and Charles Strom from the Association of Organ Procurement Organizations, the trade group that represents OPOs, argued that the metrics are too broad, evaluating OPOs partly on whether transplant centers ultimately accept organs and not fully accounting for regional differences such as age of potential donors, local rates of cancer, or how far organs must travel to reach transplant centers.

This pressure to recover more organs has also made some OPOs seem more aggressive to the clinicians working besides them. “Some people view them as vultures, which is horrible,” said Smith, the UCSF neurologist who has experienced the tension from the hospital side. “They’re trying to do their job.” Still, he added, “when you impose that [pressure], then it changes how aggressive they are.”

Both things can be true. The old system needed pressure to perform better. And pressure can create risks, or perceived risks, in a process that depends on careful judgement around a dying patient.

And the safety question isn’t a theoretical concern either. A March 2025 investigation from the Health Resources and Services Administration (HRSA), the federal agency that oversees the national transplant system, documented what can happen when those safeguards fail. In a review of attempted DCD cases at Kentucky Organ Donor Affiliates, an OPO that covered Kentucky and parts of Ohio and West Virginia, HRSA found recurring problems about staff missing vital signs in patients that raised concerns, failed to work collaboratively with hospital medical teams, failed to respect family decision-making, and documented medical data poorly. HRSA said the pattern suggested “organizational dysfunction” and a weak safety culture.

One OPO’s failure does not prove that DCD is broadly unsafe or that OPOs across the country behave the same way. But the Kentucky review showed how badly things can go when the line between patient care and organ recovery is not honored.

Since then, federal officials have been trying to close some of the gaps. HRSA has pushed for clearer family education around DCD and more standardized reporting on ventilated patients referred to OPOs, as well as opened up a reporting channel that sends misconduct concerns directly to HRSA. In a separate case, the Department of Health and Human Services also moved to shut down an OPO in South Florida after finding unsafe practices, underperformance, and paperwork errors.

Organ donation is a touchy subject, because it relies so much on the goodwill and the trust of the people who agree to give their organs so they can live on in others. But the procedural issues also matter, because there are lives at stake on both sides of the process. 

Emily Hoffman and Beth Hoffman stand together on a beach in Ocean Beach, New Jersey, in 2017, wearing sunglasses and matching dark shirts from a lifeguard tournament. Beth is on the left and Emily is on the right.

Around 13 people die each day in the US waiting for organs. In that desperate landscape, the rise in DCD has led to many lives saved and helped several more live better, fuller lives. The dearth of organs even compelled my former Future Perfect colleague Dylan Matthews to sign up as a living donor and donate his kidney to a complete stranger. (You can read his story here).

And the value of the donation is not just measured in recipients saved. For the Hoffmans, the knowledge that Emily’s organs helped others offered a solace they had not expected. Emily “gave the gift of life in her death,” Beth told me.

That is the highest ideal organ donation — and DCD – can achieve: a death already coming that still changes the lives of others in need. The case for DCD is clear, but its future depends on its proponents’ ability to protect both patients and public trust.

Clarification, July 1, 6 pm ET: A previous version of this post described how the NRP process intends to stop blood from reaching the brain, but did not acknowledge cases where that does not go according to plan. The post has been updated to include a safety notice from the Organ Procurement & Transplantation Network, which said it had received “verified reports” that blood had unintentionally reached the brain and brainstem during NRP. The post has also been updated to clarify that Dorry Segev and Nader Moazami are doctors at NYU Langone. 

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