The Centers for Medicare and Medicaid Services (CMS) has proposed the new Increasing Organ Transplant Access (IOTA) model, which aims to increase access to life-saving transplants for patients living with kidney disease while controlling Medicare costs. The IOTA is a six-year, mandatory model that would begin on January 1, 2025. It will focus on encouraging transplant hospitals to use more of the kidneys that become available for transplantation and better facilitate transplants from living donors. Comments are due July 8th. This is the second mandatory model that the Administration has released this year, signaling a shift from voluntary models.

Kidney transplantation is the best treatment for most patients with chronic kidney disease and end-stage renal disease, but more people are in need of a kidney than there are organs available. Over 90,000 people were on the waitlist for a kidney transplant in the U.S. in 2023, but only an estimated 28,000 kidney transplants were performed.

For participation, CMS would select half of the Donation Service Areas (DSAs) and all eligible kidney transplant hospitals within to participate in the mandatory model. The other half of transplant hospitals would serve as the comparison group for evaluation purposes.

Success in the model will be based on a hospital’s final performance score. Depending on how a participant scores, they will either receive upside risk payments from CMS, fall in a neutral zone (in which the hospital neither receives an upside risk payment nor owes a downside risk payment), or owe downside risk payments. The final performance score would be out of 100 points and calculated on a set of proposed metrics in three domains:

  • Achievement: Based on the number of kidney transplants, for a total of 60 points.
  • Efficiency: Based on the organ offer acceptance rate ratio, for a total of 20 points.
  • Quality: Based on the CollaboRATE Shared Decision-Making Score, Colorectal Cancer Screening, Three-Item Care Transition Measure, and a post-transplant composite graft survival rate measure, for a total of 20 points.

To lessen disparities in access to organs, the IOTA model would include health equity incentives in the form of a health equity performance adjustment in the Achievement domain. This adjustment would give participating transplant hospitals more credit for a transplant performed for a person in a defined low-income population. The model also would provide flexibilities for transplant hospitals in addressing barriers related to social drivers of health — such as food insecurity and homelessness — and require participating hospitals to establish health equity plans to identify gaps in access, similar to the current REACH model.