A recent series of near-misses in which patients scheduled for organ recovery exhibited unexpected signs of consciousness recognized only moments before initiation of surgery has triggered investigations by national bodies.1 In September 2024, a US House of Representatives committee convened a hearing to “examine efforts to strengthen oversight” and to “inquire about ongoing patient safety concerns.”1 In March 2025, the Health Resources and Services Administration (HRSA) warned that certain practices “may create potentially avoidable risk of bodily harm and death to neurologically injured patients”1 and called for development of safeguards and enhanced disclosure regarding controlled donation after circulatory determination of death (hereafter referred to as controlled donation).
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