OPTN bylaw requirements updating the definition of a transplant hospital are expected to go into effect in December 2019. The OPTN/UNOS Board of Directors approved the updated definition in December 2016 to reflect changes in the structure of many hospitals and medical systems.
The changes are outlined in a January 2017 policy notice. In summary, under the new definition, member institutions can perform transplants in more than one location if all of the locations are in one donation service area (DSA) and meet the following requirements:
- Transplant operating rooms (ORs) must have common executive leadership and governance oversight, demonstrated to satisfaction of the OPTN
- Transplant ORs must be preemptively documented with the OPTN
- Transplant ORs must also meet one of the following criteria:
- Be within a “contiguous campus”
- Be within a one-mile walking distance of the main hospital address
- Be approved at the discretion of the OPTN
Under this new definition, only one member will be allowed per campus unless the other member is a children’s or Veterans Affairs (VA) hospital.
What you need to do
In November, UNOS will send each transplant hospital an application form. Each transplant hospital will need to notify the OPTN of its intention to either remain recognized as the current, single transplant member; to separate its current membership into more than one transplant hospital member; or to merge its existing membership with other existing transplant hospital members. In addition, all transplant hospitals will be expected to provide the following information:
- Type of campus arrangement (i.e., contiguous campus, one mile walking distance radius)
- Documentation of common executive leadership and governance
- Transplant operating room documentation, including:
- Maps that illustrate the transplant hospital campus and the location of each operating room facility
- Building name and address
- Floor number
- Unit identifier
If you submit complete information, and if your hospital qualifies as a single transplant hospital using either the “contiguous campus” or the “one-mile walking distance” geographical considerations, no further action is required.
If you will be merging with another transplant hospital member or will be separating into two or more transplant hospital members, you will need to complete and submit a full transplant hospital membership application(s). If you want to request an exception to the geographic requirements, the OPTN/UNOS Membership and Professional Standards Committee (MPSC) will ask transplant hospitals with operating rooms beyond the established geographic boundaries to provide additional information as noted in the bylaws. The MPSC will also request that the transplant hospital participate in an informal discussion. During the discussion, the MPSC will expect the transplant hospital to explain their organization and why the MPSC should consider an exception to the explicit boundaries used to define a transplant hospital.
For further information
Additional information will be available soon, including a frequently asked questions document and further instructions for hospitals that anticipate a merger or separation. If you have any additional questions, please contact Nadine Drumn, Christi Manner or Tierra Yuille by phone at (804) 782-4800 or by email using the format [email protected].
