In late 2019, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule for Organ Procurement Organizations (OPOs) Conditions for Coverage. The proposed rule intends to require transparent, verifiable, and uniform metrics by which CMS can evaluate OPO performance. The American Society of Nephrology (ASN) provided comments of support and recommendations for improvement in February 2020.
The proposed rule would replace the existing outcome measures for OPO recertification with two new outcome measures that would be used to assess an OPO’s performance: “donation rate” and “organ transplantation rate,” effective beginning in 2022. The “donation rate” would be measured as the number of actual deceased donors as a percentage of total inpatient deaths in the donation service area (DSA) among patients 75 years of age or younger with any cause of death that would not be an absolute contraindication to organ donation. The “organ transplantation rate” would be measured as the number of organs procured within the DSA and transplanted as a percentage of total inpatient deaths in the DSA among patients 75 years of age or younger with any cause of death that would not be an absolute contraindication to organ donation. These important changes to evaluating OPO performance are expected to be finalized in rulemaking in the near future.
The ASN Policy team interviewed Jennifer Erickson, who served in the White House Office of Science and Technology Policy in the Obama administration, about the changes. Erickson’s portfolio included organ policy and innovation efforts. She has been a strong advocate for changing OPO regulations inside and outside of government.