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CMS Proposes New Organ Transplant Model

Faridat Animashaun
May 20, 2024

The Centers for Medicare & Medicaid Services (CMS) on May 9 proposed to implement a mandatory organ transplant model beginning Jan. 1, 2025.

The Increasing Organ Transplant Access (IOTA) Model aims to increase access to kidney transplants for individuals living with end-stage renal disease, improve the quality of kidney transplant care, reduce disparities among kidney transplant patients, and increase the efficiency of selected transplant hospitals.

Selected transplant hospitals would be eligible for upside or downside risk payments based on a final performance score calculated on metrics in three proposed domains:

  • Achievement (number of adult kidney transplants).
  • Efficiency (organ offer acceptance rate ratio).
  • Quality (post-transplant outcomes).

Participation would be mandatory for nonpediatric transplant hospitals within selected donor service areas (DSAs) with an active kidney transplant program that performed 11 or more kidney transplants annually over a three-year period. CMS has stated that DSAs will be selected at random but has not yet selected DSAs. Out of 257 transplant hospitals, 90 (35 percent) of hospitals must participate. Transplant hospitals not selected would serve as a comparison group for evaluation purposes.

The proposed model includes a health equity performance adjustment that multiplies a hospital’s achievement domain score by 1.2 times for transplants for low-income individuals, including uninsured patients, Medicaid beneficiaries, and Medicare beneficiaries.

Further, the model would offer additional performance incentives to participating transplant hospitals to improve equity in the transplant process. IOTA would require participating transplant hospitals to establish health equity plans to identify gaps in access among populations in their communities and develop strategies to close these gaps.

CMS will accept comments on the proposed model until July 16.

Contact Director of Policy Rob Nelb, MPH, at or 202.585.0127 with questions.

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