CONTACT: Sandra Remy

AOPO Submits Comments to CMS on Equity in Organ Donation and Transplantation, OPO Assessment, and Other Important Issues that Will Save More Lives

McLean, VA. (February 2, 2022) – The Association of Organ Procurement Organizations (AOPO) submitted comments today in response to the recent Centers for Medicare and Medicaid Services’ (CMS) Request for Information (RFI) on Health and Safety Requirements for Transplant Programs, Organ Procurement Organizations (OPOs), and End-Stage Renal Disease Facilities. AOPO’s comments provide recommendations on how to advance equity and reduce disparities in organ transplantation, along with focusing on stakeholder alignment and system-wide improvement in all areas.

“Continued collaboration is the only way to propel the industry forward, preserving and strengthening what works while recognizing and exploring potential improvement areas,” said Jan Finn, RN, MSN, AOPO President, and President and CEO, Midwest Transplant Network. “Together with CMS, our medical colleagues and community stakeholders, we can continue to explore innovations, information sharing, and policy alignment that can build towards AOPO’s goal of achieving 50,000 annual organ transplants in 2026.”

The association provides its expert perspective on critically important issues in organ donation and transplantation, such as equity, OPO assessment and recertification, organ transport and tracking, donor referral process, organ recovery facilities, zero organ donors and discarded organs, donation after circulatory determination of death (DCD), tissue banking, and organs for research. Following are highlights of recommendations proposed by AOPO. The full letter and AOPO comments can be found here.

Equity in Organ Transplantation and Organ Donation
Recommendation: Incentivize diverse representation on stakeholder boards and internal committees that reflect the local community.

Recommendation: CMS should invest in qualified care navigators to help guide potential recipients through the process of being referred for transplant.

To see more recommendations, click here [page 3].

OPO Assessment and Recertification and Competition

Recommendation: In addition to evaluating superior performance on each of the outcome metrics, CMS should recognize and give significant weight to sustained improvement in an existing OPO’s Donor Service Area (DSA) when evaluating that OPO in a competitive process for its DSA.

Recommendation: Upon selecting a new OPO to take over a particular DSA, the selected OPO and CMS should agree on a transition timeline that considers the unique circumstances of that particular DSA and OPO and prioritizes minimizing service disruptions.

To see more recommendations, click here [page 6].

Organ Transport and Tracking

Recommendation: CMS should collaborate with stakeholders to develop outcome metrics to evaluate the effectiveness of new tracking and shipping innovations.

Recommendation: CMS should support the development of and widespread access to innovative, affordable organ tracking and shipment solutions, including by continuing to designate innovations in this space as Medicare allowable costs.

To see more recommendations, click here [page 7].

Donor Referral Process

Recommendation: Electronic donor referrals be automatically generated when specific clinical criteria are met.

Recommendation: CMS should incentivize donor hospitals and OPOs to work toward universal use of automated electronic referrals and Application Programming Interfaces (APIs) within the organ referral process.

To see more recommendations, click here [page 9].

“Zero Organ Donors” and Discarded Organs

Recommendation: CMS should establish a set of unified industry metrics with appropriate clinical risk adjustment mechanisms that incentivize all stakeholders to expand donor pools and push the boundaries of organ transplantation to save more lives. 

Recommendation: CMS should incentivize the pursuit of “zero organ donors” as an important strategy to expand the availability of organs for transplant by counting these toward the donation metric, removing them from the denominator in the performance metric, giving a fractional credit for organs pursued with intent but not transplanted, or accounting for them as a separate metric.

To see more recommendations, click here [page 12].

“We appreciate the opportunity to work with CMS and look forward to future conversations continuing over the long term,” says Steve Miller, CEO, AOPO. “As the leader of the OPO community, it is imperative that we provide this kind of input, sharing best practices, that will lead to more transplants, greater organ donations, and more lives saved.”

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The Association of Organ Procurement Organizations (AOPO) is the not-for-profit trade association leading the nation’s organ donation community to save and improve lives through organ, eye, and tissue donation. Founded in 1984, AOPO advances organ donation and transplantation by driving continual improvement of the donation process, collaborating with stakeholders, and sharing successful practices with their OPO members. The vision of AOPO is to pursue the day when every donation opportunity results in lives saved. For more information, please visit