Widespread Underreporting by Hospitals

The Ministry of Health issued two regulations that indicated widespread, extensive underreporting by transplant centers in Mainland China:

  • The Ministry of Health Medical Regulation Notice #55 of 2009 included a zero-tolerance policy of suspending the transplant approval of any hospital found not in compliance with human organ transplant reporting requirements.1
  • The Ministry of Health Medical Regulation Notice #105 of 2010 required all transplantations be reported within 72 hours of being performed. Hospitals found to be in violation would have their transplant qualifications suspended.2

After these notices were issued, has the situation changed?

In April 2011, The Economic Observer’s report titled “Who can solve the difficulties in organ donation in China?” demonstrated that wide gaps exist between the reporting and registration system used by transplant centers and the real number of transplant surgeries.3

The article cited an example in which Tianjin First Central Hospital (Oriental Organ Transplant Center) registered only 7 liver transplants (including those from both living and cadaveric donors) in 2010, yet its publicly reported liver transplant figure was 330. Hospital president Shen Zhongyang and Wang Haibo, who managed the National Liver Transplant Registry at Hong Kong University’s Queen Mary Hospital, both declined to explain this discrepancy.

Per our earlier analysis, this hospital’s transplant volume is at least 6,000 to 8,000 per year and may have reached as high as 7,800 to 10,400 per year. Its registered volume is not even a tiny fraction of the actual number of transplant surgeries. Its transplant center claims to have performed the most transplants in the entire country and was ranked first in the registration system consistently for more than a decade. This suggests that other transplant centers might have registered even fewer than 7 transplants per year.

From this example, we can see that underreporting among China’s transplant centers can be described as “severe.” The transplant statistics reported by government authorities must therefore be far from reality.


"The Ministry of Health Medical Regulation Notice (2009) #55"
Original: http://www.moh.gov.cn/zwgkzt/s9968/200908/42294.shtml
Archived: http://web.archive.org/web/20161205110116/http://www.moh.gov.cn/zwgkzt/s9968/200908/42294.shtml
"The Ministry of Health Medical Regulation Notice (2010) #105"
Original: http://www.nhfpc.gov.cn/zhuzhan/wsbmgz/201304/d43ba2c1bfb74615a2c10bed02073d49.shtml
Archived: http://web.archive.org/web/20161205105713/http://www.nhfpc.gov.cn/zhuzhan/wsbmgz/201304/d43ba2c1bfb74615a2c10bed02073d49.shtml
"Who can solve the difficulties in organ donation in China? Source: Economic Observer, dated: April 6, 2011"
Original: http://www.shenyounet.com/?action-viewnews-itemid-3936
Archived: https://archive.is/jR3ZG
中国器官捐献之困谁人能解? 来源:经济观察报 2011年4月06日