Organ donor hospitals and transplant hospitals – how do they differ?

Hospitals throughout the United States play vital roles in saving and enhancing lives through organ donation and transplantation. But an individual hospital’s responsibilities can differ, depending on whether it is a donor hospital or a transplant hospital.

Donor hospitals

More than 5,000 hospitals in the United States have the potential to admit and care for people who may become organ donors. These range from small, rural community hospitals to major metro trauma centers – any facility with intensive or advanced acute care capabilities. Potential organ donors may meet medical criteria for donation either via brain death (complete, irreversible loss of brain function) or donation after circulatory death (DCD), occurring and pronounced in a hospital setting.

Donor hospitals are responsible for declaring patient death according to applicable state law and accepted medical practice. In addition, all donor hospitals must comply with state and federal laws and regulations regarding identification and referral of potential organ donors to their assigned organ procurement organization (OPO). In general, donor hospitals are overseen by the Centers for Medicare & Medicaid Services (CMS). CMS provides regulations, including conditions of participation, that apply to all hospitals seeking Medicare reimbursement.

Donor hospitals are not members of the national Organ Procurement and Transplantation Network (OPTN) and are not subject to OPTN policies and requirements unless they are also a transplant hospital. The national OPTN, overseen under contract by the federal Health Resources and Services Administration (HRSA), does not have policies governing donor hospitals. The OPO managing the logistics of the donation process is, however, accountable to CMS requirements and to OPTN policies and bylaws.

Transplant hospitals

There are 251 hospitals in the United States accredited to perform transplants of at least one organ type. Each of these hospitals is accountable to state and federal standards for quality of patient care and ensuring patient safety. CMS has a number of applicable regulations and conditions of participation that apply specifically to transplant hospitals.

Each transplant hospital must also be a member of the OPTN and must abide by the OPTN policies and bylaws that govern the transplant process and standards for ensuring patient safety.

Can a donor hospital also be a transplant hospital?

Yes, an individual institution can be both a donor and a transplant hospital. As a transplant hospital, it must be an OPTN member and meet the standards the OPTN establishes. But if it is functioning in its donor hospital capacity, there are no additional OPTN standards or requirements that would apply to it.

The majority of donor hospitals in the United States are not OPTN members and would not be compelled to become OPTN members by any law or regulation. However, they remain responsible for all other state or federal requirements that apply to any part of the donation process.