External Panel Urges Harvard to Implement Internal Policies, Improve Tracking for Anatomical Gift Program

An external panel released recommendations for changes to Harvard Medical School’s Anatomical Gift Program Thursday morning, nearly six months after its morgue manager was accused of stealing organs and other parts of cadavers donated for medical research.

The panel’s 24-page report, completed Nov. 22, did not include factual findings about the thefts themselves, instead issuing recommendations for updating AGP’s operations, hiring processes, staffing structures, and cadaver tracking systems. The panel also advised AGP to develop standardized, centralized policies and procedures for the morgue and update existing ones.

In June, former HMS morgue manager Cedric Lodge was indicted on counts of conspiracy and aiding and abetting the interstate transportation of stolen goods. Lodge pleaded not guilty in June. Class action lawsuits from family members of cadaver donors against the University soon followed, as did further prosecution of the alleged human remains trafficking network that sent parts of the cadavers across the country.

In an email to HMS and School of Dental Medicine affiliates, University Provost Alan M. Garber ’76 and HMS Dean George Q. Daley ’82 said that HMS Dean for Medical Education Bernard S. Chang ’93 will chair a task force dedicated to reviewing and creating an implementation plan for the recommendations made by the panel.

“We take our responsibility for oversight of the Anatomical Gift Program seriously,” the administrators wrote. “We owe it to our community, and especially to our anatomical donors and their loved ones, to ensure that Harvard is worthy of those who, through selfless generosity, have chosen and will in the future choose to advance medical education and research.”

The panel, whose report was initially scheduled to release at the end of the summer, consisted of three members from outside the University — Sally S. Aiken, the retired chief medical examiner of Spokane County; Robert J. McKeon, the director of Emory University School of Medicine’s body donor program; and Brandi Schmitt, the director of anatomical services at the University of California.

According to the report, the panel conducted multiple interviews, reviewed AGP documents, and visited the facilities this summer.

Harvard does not have policy specific to the AGP, per the report, nor to the use of human specimens for education and research. In addition to recommending that the University write and implement such a policy, the panel advises AGP to regularly update its Standard Operating Procedure Manual to include information on required documentation of donor specimens, specimen tracking standards, maintenance of inventories, and training requirements. The SOPM has not been updated since 2014.

The panel recommended that the AGP regularly review its donation consent form, which was updated in 2022 for the first time since 2003. Specifically, the report advises the AGP to explain the possible uses of data and images of donated bodies, as well as the storage of that information.

The AGP receives donations from people who register their bodies for medical research by HMS prior to their deaths. Currently, the three-person AGP staff determines a donated body’s suitability for use, but they are not trained in clinical medicine and have limited training for the task of evaluating a donated body. To lighten the staff’s workload, the panel recommends appointing a medical director to advise on donor eligibility and suitability for the AGP, as well as an anatomy laboratory technician to maintain the laboratory.

The panel also recommended changes to the AGP’s system of oversight, including the creation of a small operational committee and governing board. The committee would supervise the morgue and laboratories daily, while the governing board would meet annually to ensure long-term oversight.

Other suggestions included creating a consistent protocol for tracking and identifying cadavers throughout their educational use, perhaps through the establishment of a workstation near teaching laboratories dedicated to tracking the location changes of donor bodies and donor specimens at all times.

The report also noted that the AGP possesses a “legacy collection of skeletons and bones,” in part acquired through “unknown provenance.” Though the panel did not investigate this collection directly, it urged the Medical School to investigate the collection for any remains of Indigenous people in accordance with federal repatriation laws.

Such collections are not unusual and can be found at other medical schools throughout the U.S., the report added, often containing remains acquired through unethical practices.

“Most were purchased as medical teaching specimens in a manner that was legal at the time but may not have been ethical,” the report reads. “The panel recommends that the skeletons and bones be assessed by experts and that any regulatory requirements like those found in the Native American Graves Protection and Repatriation Act be applied, as needed.”

Harvard has been embroiled in controversy surrounding its possession of the remains of Indigenous people, though most of the attention has gone to the University’s museums, which were found to contain the remains of more than 7,000 Indigenous people in 2022. The University has since pledged to repatriate these remains, a process that remains ongoing.

The panel recommended that Harvard establish “respectful” procedures for all human skeletal remains held in its care, from storage to disposition, given that such regulations do not currently exist. The report also suggested the program could “explore opportunities to teach about consent and past transgressions related to how human remains have historically been obtained for research and education.”

In their email, Garber and Daley wrote that the report will help “ensure that the program adheres to the highest standards and best practices.”

“An anatomical donation is among the most altruistic acts and deserves our attention and profound respect,” they wrote.

—Staff writer Jade Lozada can be reached at jade.lozada@thecrimson.com.

—Staff writer Ammy M. Yuan can be reached at ammy.yuan@thecrimson.com.