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AAMC Comments on CMS Transplant Request for Information

February 4, 2022

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CONTACTS
Mary Mullaney, Director, Hospital Payment Policies

The AAMC submitted comments on Feb. 1 in response to the Centers for Medicare & Medicaid Services’ (CMS’) request for information (RFI) on potential changes to the requirements for transplant programs and increasing the use of marginal organs. 

The RFI specifically asked if patients on the transplant waitlist should be informed that an organ has been offered to them at the time it is offered. The association noted that in “current practice, transplant programs already notify patients that an organ was offered but was not a suitable match. This information, however, is generally not provided to the patient at the time the organ is offered as these offers occur at all hours. When this happens, it allows organs to be released to other patients on the waitlist. The entire organ offer process could be substantially slowed to the detriment of other waitlisted patients and the system as a whole if additional requirements are implemented.”

The letter reiterated AAMC-member transplant programs’ intent to transplant all organs whenever possible unless an organ is not suitable for a patient. Increasing the “use of marginal organs will increase the supply of available organs,” the association noted, but there is “complex, clinical decision-making associated with each transplant decision. ... Many organs that are not transplanted have acceptable rationales for not being used,” and these are reported to the Organ Procurement and Transplant Network.

Finally, the letter asked the CMS to consider ways to increase educational efforts to decrease the prevalence of disease that leads to patients needing transplants, noting that earlier referrals to specialists should also be encouraged. 

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