The $65,912 of unallowable costs tallied by OIG included costs incurred for donations and gifts, the retirement party, entertainment, lobbying, and meals. Federal inspectors estimated that Medicare’s share of the unallowable costs related to kidney procurement was $33,431.
CTDN agreed with many of the OIG findings, but also defended some of the expenses as reasonably associated with fundraising, publicity, and raising public awareness, including events such as the Donor Family Gathering, which allows transplant recipients and their families to thank and share their stories with organ donors and their families.
"In order to participate in community events that provide a forum for community outreach and education CTDN is often asked to contribute to the cost of the event as funding for these types of activities is extremely limited," Siljeslrom wrote. "Volunteers are recruited as additional resources for the events. CTDN occasionally identifies a small way to thank those who volunteer to support this part of our mission. Hence the gifts to non employees."
CTND said it had documented the $99,188 identified by OIG as unsupported "and believes that all the costs are legitimate." However, CTND concurred that the documentation was inadequate.