Two Texas OPOs Become Gift of Life Alliance: Can Scale and Local Trust Coexist?

On October 1, Southwest Transplant Alliance (STA) of Dallas and Texas Organ Sharing Alliance (TOSA) of San Antonio began operating as one organ procurement organization, Gift of Life Alliance (GOLA). GOLA says it will serve more than 19 million people in 145 Texas counties, with about 700 employees. The organizations say CMS approved the merger.

Quick note so nobody gets mixed up: GOLA is separate from Gift of Life Michigan and Gift of Life Donor Program in the Philadelphia area, both of which are on CMS's list of OPOs.

What happened

The plan was first announced in September 2025, aiming for the beginning of 2026, pending CMS approval (TOSA's announcement said the same). In mid-September 2026, STA and TOSA both posted that the merger would happen October 1.

Brad Adams, formerly STA's CEO, is GOLA's President and CEO, and Joe Nespral, formerly TOSA's CEO, is Chief Strategy Officer.

For hospitals, the message so far is continuity. According to the launch announcement, hospitals and partners "will continue to receive the same dedicated support from existing teams," and the main visible changes at first are the new name and logo. Full integration of the two nonprofits will continue over the coming months.

On the regulatory side, federal rules treat an OPO merger as a change in control or ownership. The OPO has to notify CMS before putting it into effect, and a change to a service area needs prior CMS approval. I couldn't find a separate public CMS notice or Federal Register entry on STA, TOSA or GOLA, so for now what we know comes from the organizations themselves.

Why it matters

Most OPO reform talk lately has been about metrics. Under CMS's 2020 final rule, each OPO is scored on a donation rate and an organ transplantation rate, both measured against the donor potential in its donation service area. OPOs then land in one of three tiers: the top group is recertified, the middle group has to compete to keep its DSA, and the bottom group gets an initial decertification determination (42 CFR 486.316 and 486.318).

The 2022–2026 recertification cycle ended July 31, 2026, current OPO agreements run through January 31, 2027, and this is the first cycle where the outcome measures and tiers are used for recertification. As of late September, CMS had not published final tier rankings, and the newest performance report on CMS's QCOR site was still the July 2025 interim report.

We have also seen the far end of that process. In September 2025, HHS moved to decertify Life Alliance Organ Recovery Agency in Miami, and in January 2026 CMS approved Nevada Donor Network to take over organ procurement in the Southern Florida DSA after a competitive selection process. In Kentucky, CMS says it will decertify Network for Hope on November 3, 2026, an action HHS tied to patient safety failures rather than to the tier rankings.

Mergers aren't brand new, either. CMS's July 2025 report notes list LifeChoice Donor Services merging with New England Organ Bank as of January 1, 2021, and Washington Regional Transplant Community merging with The Living Legacy Foundation of Maryland as of January 1, 2023. And CMS's pending proposed rule would let one OPO hold more than one DSA after a change in control or ownership, and either consolidate them or keep them separate. That is a proposal, not law, and no final rule has been published.

Scale versus local

Here is what I keep coming back to. Nearly all of that is about measuring OPOs and deciding who keeps a service area. GOLA is a different model: two existing OPOs combining their teams, infrastructure and resources. Could consolidation become a bigger part of the future of OPO reform? I think it's a fair question.

Scale has real advantages, in general. A larger organization may be able to support things a smaller one struggles to sustain: donor care units, perfusion capability, specialized clinical teams, transport, technology and more standardized donor management. To be clear, GOLA has not announced any new facilities or clinical programs. Its predecessor organizations already operated their own recovery facilities, STA's Legacy Center in Dallas and TOSA's Center for Life at University Hospital in San Antonio.

But procurement is local. Good cases depend on relationships: the charge nurse who calls early, the intensivist who trusts you with the family, the hospital leaders who know your name. That trust between coordinators and ICU teams gets built over years, one case at a time. It doesn't transfer automatically on a launch date.

So the real question, for me, is whether you can get the benefits of scale without losing the local relationships that make donation possible.

What this means for OPCs

Hospital relationships. The basics stay the same. Hospitals must have an agreement with their designated OPO and notify it in a timely manner about patients whose death is imminent or who have died (42 CFR 482.45). OPOs need written agreements with 95 percent of participating hospitals in their service area that have a ventilator and an operating room, and those agreements must define "timely referral" and "imminent death" (42 CFR 486.322). Questions I'd watch:

  • Will referral phone numbers or electronic referral systems change, and how will hospital staff hear about it?
  • Will hospital agreements be reissued under GOLA's name?

Protocols. Two OPOs means two sets of policies, and coordinators live inside those every shift.

  • Will clinical protocols, including DCD and NRP practices and donor management, be harmonized, and on what timeline?
  • Will the two former DSAs be scored as one for CMS outcome measures?

Careers and hiring. GOLA has about 700 employees and has already named a vice president of Hospital Services. If you work there now or are thinking about applying:

  • Will coordinator roles, regions or call centers be restructured?
  • For the rest of us: if more mergers come, how will that change where the jobs are and what they ask of coordinators?

What I'll be watching

I'll be watching how GOLA's integration goes over the coming months, especially at the bedside, where hospital staff and coordinators will feel it first. And I'll be watching whether more consolidation follows. If it does, I hope we keep asking the same question each time: what happens to the relationships that make donation work?

Sources

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