AHPA submitted comments on: CMS-5544-P: Medicare Program: Alternative Payment Model Updates and the Increasing Organ Transplant Access Model.

Click here for the full comment letter. Below are some key takeaways.

  • Adopt fairer, risk-adjusted measures of transplant-center performance:
    AHPA strongly supports incorporating recipient and donor characteristics, such as age, diabetes status, and kidney function, into the composite graft survival measure. It also supports excluding multi-organ transplants because their greater clinical complexity and risk could distort comparisons among transplant centers.
  • Reconsider semiannual organ-declination notices to waitlist patients:
    AHPA raises concerns that notifications listing the number of organ offers declined and the reasons for those decisions may not provide actionable information and could confuse patients. If CMS finalizes the requirement, AHPA recommends clearly defining which declinations must be reported, particularly when a patient is temporarily inactive or medically unable to receive a transplant.
  • Develop waitlist-notification policies consistently across the transplant system:
    AHPA opposes creating a waitlist-status notification requirement that applies only to IOTA participants. It recommends addressing such requirements through the Organ Procurement and Transplantation Network so that patients and transplant centers are subject to consistent national standards, regardless of IOTA participation.
  • Provide flexible, modern communication options for Medicare beneficiaries:
    AHPA supports flexibility in how transplant centers deliver beneficiary notifications and recommends making electronic communication the standard option rather than limiting it to patients who have opted out of paper communications. It also asks CMS to clarify whether the requirements apply to Traditional Medicare beneficiaries, Medicare Advantage enrollees, or both.
  • Limit duplicative monitoring and address allocation policies through broader national processes:
    AHPA recommends that CMS clarify due process, corrective-action opportunities, and coordination with existing enforcement mechanisms before terminating an IOTA participant. It also opposes addressing Allocation Out-of-Sequence practices solely through IOTA because transplant centers do not control national organ allocation. AHPA recommends handling the issue through OPTN and regulatory processes applicable to all transplant programs.