PUBLIC STATEMENT
Media Contact:
Jenny Daigle | jdaigle@aopo.org
AOPO Guidance on the Alignment and Use of Organ Procurement Organization Quality and Performance Measures
McLean, VA (July 17, 2026) – 53 of the nation’s 55 Organ Procurement Organizations (OPOs) announced a quality improvement framework, Driving Progress in Organ Donation and Transplantation Through Strategic Measurement and Continuous Quality Improvement. The framework outlines eight priority areas for measurement designed to advance quality, accountability, and collaboration across the organ donation system while supporting continued growth in organ donation and transplantation for the donor families, transplant patients, donor hospitals, transplant centers, and communities it serves.
The framework builds on the continuous quality improvement (QI) initiatives that OPOs have engaged in for decades. It intends to strengthen transparency, accountability, and trust while ensuring oversight reflects how the organ donation system functions. Along with using standard practices in healthcare organizations for quality and performance, all OPOs are required by the Centers for Medicare & Medicaid Services (CMS) to maintain Quality Assessment and Performance Improvement (QAPI) programs under 42 CFR § 486.348. Some OPOs have also chosen to pursue additional approaches for QI, including the Association of Organ Procurement Organizations (AOPO) OPO IMPACT Program and the Baldrige Performance Excellence Program™.
The framework was developed in response to longstanding recognition that no single measure can fully capture OPO performance and that meaningful quality improvement requires evaluating multiple aspects of the donation process. While the current CMS OPO Final Rule relies primarily on two outcome measures—donation rate and transplantation rate—to assess performance, these measures do not account for differences across donation service areas. They also hold OPOs accountable for outcomes that are influenced by factors beyond their control and provide limited insight into the operational improvements needed to enhance performance. A more comprehensive measurement approach includes structure, process, outcome, and safety measures and is necessary to support continuous improvement, identify best practices, and strengthen system performance.
The new QI framework provides a unified and overarching vision for the measurement of OPOs that will enable them to work together and with other stakeholders to better honor donors and their families and serve individuals on the transplant waiting list nationally.
AOPO supports this framework, its three aims, and the eight measure areas to strengthen public trust and collaboration in the organ donation system. The three aims are promoting process excellence, ensuring donor and recipient safety, and driving system outcomes. The eight measure areas include both process and outcome measures that were developed using the CMS Blueprint Measure Lifecycle. The measures include: 1) Referral Rate, 2) Approach Rate, 3) Authorization Rate, 4) Donation Rate, 5) Donor Management Goals Bundle, 6) Organs Recovered Per Donor, 7) Organ Utilization Rate, and 8) Donor and Recipient Safety.
AOPO has submitted the first four measures for endorsement consideration by the Partnership for Quality Measurement (PQM), with additional measure areas continuing to advance through the development and validation process. The framework enables alignment of measures across stakeholders in the donation and transplantation system to ensure that all aspects of the system are working together.
AOPO is committed to the measurement of quality and performance in OPOs and recognizes the importance of this work in saving as many lives as possible. The Association launched this initiative because healthcare quality experts generally recognize that performance is best understood through a balanced set of measures that evaluate different aspects of care and operations, rather than relying on a limited number of outcome metrics.
AOPO also recognizes that Congress reflected its understanding that structure, process, and outcome measures are critical to the donation and transplantation system in the National Organ Transplant Act of 1984. AOPO further recognizes there are best practices in the development and use of healthcare quality and performance measures. Therefore, AOPO seeks to use CMS guidance for measure development, maintenance, and implementation, and to work with policymakers to ensure OPO measures are used appropriately to improve care and system performance.
Healthcare quality and performance measures are primarily intended to drive improvement, while also supporting benchmarking and accountability. AOPO supports an accountability system that is evidence-based, data-driven, and ensures stable access to organ donation and transplantation services nationwide.
The framework’s eight measurement areas were intentionally designed to provide a more complete view of performance across the donation process, from referral and family authorization through donor management, organ recovery, organ utilization, and safety. Together, these measures can help identify opportunities for improvement that may not be visible through outcome measures alone.
No single measure can fully capture OPO performance. This principle was a key driver behind the development of the framework. Likewise, composite scoring across multiple measures, rankings, and comparisons to the mean can obscure important details in performance and limit opportunities to identify, share, and adopt best practices. AOPO therefore recommends evaluating process and outcome measures individually as part of a comprehensive oversight approach which also includes site surveys, quality improvement activities, and other tools that support patient safety, accountability, and continuous improvement.
AOPO further believes measures used within the Medicare and Medicaid Conditions of Participation should be carefully evaluated to ensure they are fit for their intended purpose, appropriately validated, and implemented in ways that support quality improvement. Measures that are used outside of their intended purpose or without sufficient context may create unintended consequences, including stakeholder confusion, reduced trust in the donation system, and increased regulatory and operational costs without corresponding improvements in outcomes.
AOPO encourages donor hospitals, transplant centers, and policymakers—including CMS—to align around a common measurement framework to collaborate in working toward the triple aims of process excellence, organ donor and transplant recipient safety, and driving system outcomes. Shared goals with aligned measures will strengthen collaboration across the organ donation and transplantation system, help increase the number of organs available for transplant, and save more lives among the more than 100,000 people currently on the transplant waiting list.
Learn more about the OPO Performance Measurement Project at https://aopo.org/opo-metrics-project/.