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CMS Issues RFI on Medicare Organ Transplant Program Requirements

December 3, 2021

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CONTACTS
Andrew Amari, Hospital Policy and Regulatory Specialist

The Centers for Medicare & Medicaid Services (CMS) issued a request for information (RFI) on Dec. 1 that seeks public comments on potential changes to the requirements that transplant programs, organ procurement organizations, and end-stage renal disease (ESRD) facilities must meet to participate in the Medicare and Medicaid programs.

Specifically, CMS has solicited comments on five topics: improving systems of care for transplant patients, increasing the number of organs available for transplant, encouraging alternative dialysis settings where appropriate, ensuring CMS policies appropriately incentivize the creation and use of future new treatments and technologies, and harmonizing requirements across agencies to facilitate these objectives. Notably, CMS has requested that transplant programs provide feedback on incentives and barriers to providing quality organs, transparency and communication with patients on the waiting list, and improving equitable access to organs, among other topics.

CMS elected to engage in separate rulemaking on the organ transplantation requirements after receiving comments that the agency’s proposed changes to the requirements in its fiscal year (FY) 2022 Inpatient Prospective Payment System (IPPS) proposed rule did not holistically consider the impact of the changes on the transplantation system [refer to Washington Highlights, Aug. 6]. The agency’s RFI addresses comments from the AAMC and other stakeholders on the FY 2022 IPPS proposed rule that urged CMS to engage all transplant stakeholders to best evaluate the impact of changes to the transplantation requirements and ensure continued availability and access to scarce organs [refer to Washington Highlights, July 1].

CMS is looking for comments from organizations and individuals engaged in the transplant system — including transplant programs, organ procurement organizations, and ESRD facilities — as well as transplant donors, recipients, and family members. Comments on the RFI are due to CMS by 5 p.m. on Feb. 1, 2022.

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