AOPO Submits Recommendations to CMS on Improving Organ Donation and Transplantation

It has been a busy time as the Association of Organ Procurement Organizations (AOPO) worked with its members on comments submitted this week in response to the recent Center 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 improvements.

We developed our recommendations with our 50,000 Annual Organ Transplants in 2026 campaign as the framework of the discussions. What is abundantly clear as we share our insights and ideas is that collaboration is the only way to propel the industry forward, preserving and strengthening what works while recognizing and exploring potential improvement areas. Together with CMS, our medical colleagues and community stakeholders, we can continue to explore innovations, information sharing, and policy alignment that can build toward AOPO’s goal.

Our recommendations provide OPOs’ expert perspectives on critically important issues in organ donation and transplantation, such as equity, OPO assessment and recertification, organ transport and tracking, and the donor referral process. We also addressed 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

: AOPO recommends CMS 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

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

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

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 are working with CMS as a trusted partner in representing OPOs and their roles in the donation and transplantation process, and we look forward to future conversations continuing over the long term. As the leader of the OPO community, it is imperative that we share our perspective and best practices, that will lead to increased organ donations and ultimately more lives saved through transplantation.

Steve Miller, MBA, CAE

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