Establish better metrics for OPOs and transplant hospitals

Issue

Holding OPOs and transplant hospitals accountable for their performance, and helping them to improve and save more lives, requires consistent, reliable and timely metrics.

To better measure OPO performance, CMS has proposed a new metric that relies on death certificate data collected by the Centers for Disease Control and Prevention (CDC). However, the CDC itself has acknowledged death certificates are not consistently accurate, often offering incomplete data, and are unsuited for regulatory use. Death certificate data are outdated and lack the level of clinical detail required to determine donor suitability, such as information about whether the patient died on a ventilator, the potential donor-transmitted disease risk and details of medical treatment provided shortly before death.  

The organ donation and transplant community agrees that we need better data collection practices, but the proposed CMS rule is not the way to get there.

Solution

Automated donor referrals would provide an improved, independently reported and timely data source as well as the opportunity to better understand donor potential. They would be based on clearly established criteria for the completeness of information and the clinical thresholds established by the OPO to report potential donors. This hospital-reported, patient-level data could be used to calculate a clear metric suitable for CMS to use to assess and improve OPO performance. Transmitted independently and directly from the donor hospitals’ electronic medical records, this data should provide sufficient clinical detail to assess if the conditions of a death were consistent with the potential for organ donation. Other stakeholders also have recommended calculating a performance metric using this more accurate data.

Action

CMS, which has regulatory oversight over OPOs, should revise its proposal to use donor criteria rather than death certificate data. CMS should require or encourage all donor hospitals to provide this data—through automated donor referrals or the already required death records review process—and use directly reported ventilated death data from hospitals electronic medical records, a highly accurate source of data for calculating donor potential. Further, OPOs and transplant programs should be evaluated on a dashboard of metrics that reflects multiple aspects of performance and allows us to identify performance improvement opportunities.

Did you know?

• Only 1% of people die in a way that makes them medically eligible to donate their organs.
• In order to donate, patients must die while on a ventilator and meet stringent criteria to prevent possible donor-disease transmission.