Protecting the Gift of Donation: Why AOPO Spoke Out on CMS’s Proposed Reimbursement Changes

Every day, Organ Procurement Organization (OPO) team members work alongside donor families, hospitals, transplant centers, and countless healthcare professionals to make organ donation possible. The work is complex, time-sensitive, and deeply human. It requires around-the-clock clinical readiness, extensive hospital partnerships, public education efforts, family support services, transportation coordination, and continual investments in innovation.

This complex and highly collaborative work is why AOPO recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding proposed changes to how OPOs are reimbursed for non-renal organ acquisition costs. While we share CMS’s commitment to accountability, transparency, and stewardship of public resources, we are concerned several aspects of the proposal could create unintended consequences for the nation’s organ donation and transplantation system.

A System Delivering More Lives Saved Than Ever

The United States continues to make remarkable progress in organ donation and transplantation. In 2025, more than 46,000 organs from deceased donors were transplanted, resulting in more than 40,000 lives saved. OPOs have been central to growing the number of organs transplanted from deceased donors by helping identify donation opportunities, supporting donor families, managing the recovery process, and ensuring organs reach patients in need.

At the same time, the donation system is navigating significant change. OPOs are in the midst of an unprecedented recertification process, facing new regulatory requirements, expanded survey activities, and potential service area competition. Against this backdrop, CMS has proposed a fundamental restructuring of non-renal organ acquisition reimbursement.

Why Reimbursement Stability Matters

Unlike many healthcare organizations, OPOs must maintain continuous readiness regardless of when a donation opportunity occurs. Donation does not happen on a schedule. OPOs must be prepared 24 hours a day, seven days a week, 365 days a year to respond when families say “yes” to donation. This requires highly trained clinical teams, transportation networks, laboratory services, donor management capabilities, and family support resources that must remain available at all times.

AOPO’s comments emphasize that reimbursement policies should recognize these unique operational realities. Policies that introduce significant financial uncertainty, delayed reimbursement, or large retrospective repayment obligations could make it more difficult for OPOs to invest in staffing, technology, innovation, and organ utilization initiatives, which ultimately help save more lives.

Preserving Innovation and Organ Utilization

The donation community has made substantial investments in recent years to increase the number of organs transplanted. Advances such as machine perfusion technology, enhanced organ tracking systems, improved transportation logistics, and expanded data-sharing capabilities have helped make more organs available for transplantation. AOPO’s comments highlight concerns that a reimbursement model effectively operating at or near cost would reduce the flexibility needed to continue investing in these innovations.

Innovation is not a luxury in organ donation—it is a necessity. Every improvement in preservation technology, allocation, transportation, and donor management creates new opportunities to honor a donor’s gift and save additional lives.

Protecting Donor Families and Public Trust

Perhaps most importantly, AOPO urged CMS to recognize that organ donation extends far beyond the clinical recovery of organs. OPOs provide grief support, donor family aftercare, remembrance events, public education, donor registration outreach, and hospital education programs. These activities help families navigate loss, build public trust in donation, and encourage future generations of donors.

Public trust remains the foundation of the donation system. Families who feel supported and informed often become powerful advocates for donation in their communities. Efforts to educate the public, support donor families, and engage healthcare professionals are not ancillary activities—they are essential components of a successful donation system. AOPO therefore encouraged CMS to continue recognizing these activities as reasonable and necessary costs.

A Path Forward

AOPO and OPOs have long supported oversight and accountability, such as appropriate auditing, transparency, and responsible use of public funds. Our recommendations focus on ensuring any changes are carefully evaluated, phased in thoughtfully, and implemented in a way that preserves the stability of the donation system.

Among other recommendations, AOPO urged CMS to:

• • • Maintain the current reimbursement framework for non-renal organ acquisition costs.
    • Utilize targeted oversight and audit mechanisms rather than universal retrospective reconciliation.
    • Preserve support for donor family services, public education, hospital engagement, and workforce development.
    • Ensure reimbursement policies support continued innovation and organ utilization efforts.
    • Provide clear guidance, stakeholder engagement, and appropriate transition periods before implementing any significant changes.

Keeping the Focus on Patients

At its core, this conversation is about people. It is about donor families who make an extraordinary decision during one of the most difficult moments of their lives. It is about patients waiting for a life-saving transplant. And it is about ensuring the professionals who make donation possible have the resources and stability needed to honor every donation opportunity.

Policy changes should advance the goal of saving more lives through organ donation and transplantation. We appreciate CMS’s willingness to engage stakeholders on these important issues and look forward to continued collaboration to strengthen the nation’s donation system while preserving the trust, innovation, and operational readiness that make transplantation possible.

“AOPO thanks the members of the Advocacy Committee, Finance Committee, and AOPO Board of Directors for their time, expertise, and thoughtful input throughout the development of these comments.”

Thank you,
Steve Miller, MBA, CAE
AOPO CEO