AOPO Shares Impact of Proposed CMS Reimbursement Changes on the Organ Donation and Transplantation System;

OPOs Come Together in Washington to Meet with Congress

It’s been an important week at the Association of Organ Procurement Organizations (AOPO). We submitted comments to the Centers for Medicare & Medicaid Services (CMS) on proposed organ acquisition reimbursement changes included in the proposed 2023 Hospital Outpatient Prospective Payment System (OPPS) Rule. We also welcomed our member OPOs for Advocacy Day where they met with Congressional leaders on Capitol Hill to educate them about the organ donation and transplantation process.

AOPO Hospital OPPS Rule Recommendations

In our letter, AOPO emphasized our shared goal with CMS to continue to improve the organ donation and transplantation system and expand the overall number of organ transplants to save more lives. We point out how some of the proposed changes to reimbursement policies for organ procurement organizations (OPOs) could cause logistical system-wide disruptions, reduce resources, and ultimately reverse recent progress by OPOs and other stakeholders to expand the number of deceased donor transplants for the 11th consecutive year in a row.

Specifically, AOPO made the following recommendations:

      • Continue allowing organs originally procured for transplant purposes, but later deemed unusable and subsequently donated to research, to qualify as allowable Medicare organ acquisition costs. This important clarification will allow potentially groundbreaking research to continue.
      • Prior to making any changes to reimbursement policies for non-renal organs or Medicare’s share of standard acquisition charges, implement a system that provides OPOs access to up-to-date, real-time payer data that is available at the point of organ placement to avoid potential delays and disruptions.
      • Reconsider a proposal to reconcile non-renal organs retroactively financially in the same way kidneys are currently. Due to the far less frequent and predictable nature of non-renal organs, applying this same reconciliation policy would force OPOs to increase financial reserves and take a more conservative approach to budget forecasting. This would undercut their ability to continue investing in community outreach, innovations, and other important activities that have been pushing the boundaries of transplant and led to increased transplantation rates.

AOPO Requests Time Extension for Request for Information Data

In addition to the above comments, we also requested an extension on the request for information elements of this rule to allow us and our OPO members sufficient time to collect and analyze data and provide more detailed responses to quantitative questions noting that several of our members have made separate data requests to the United Network of Organ Sharing and many are still awaiting responses. We also suggested that a multi-stakeholder workgroup would be the most effective way to engage in a meaningful discussion with CMS and advance some of these multifaceted proposals which impact a multitude of stakeholders and elements of this complex system.

These are some outstanding questions that speak to the complex nature of the proposals included in this rule. We believe it is vital for CMS to consider all the stakeholder comments, downstream impacts, and logistical considerations before proceeding with proposals with this degree of potentially significant implications.

Advocacy Day

These topics will also be a focus of AOPO’s Advocacy Day where our member OPOs will meet with their Congressional representatives and staff to educate them about challenges currently facing OPOs and the organ donation and transplantation system.

This is an opportunity for our member OPOs to go to Capitol Hill and tell our Congressional representatives about the complex process of organ procurement and transplantation. Part of our mission is to educate policymakers on the important challenges facing OPOs and the transplant system more generally so that together, we can save more lives and achieve our goal of 50,000 annual organ transplants in 2026.

Thanks to those who have participated in creating our Hospital OPPS Rule comments to CMS, and to those who left home to be in Washington, DC, for Advocacy Day. Together is how we will save more lives.

Steve Miller, MBA, CAE

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