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Actions to strengthen the U.S. organ donation and transplant system

Oversight: Enhance oversight and increase transparency of peer review process


Oversight of the system has been an ongoing topic of discussion and clarification. UNOS has contacted CMS leadership to initiate formal coordination between UNOS and the OPTN, HRSA and CMS. Through this coordination, communication will be improved so that both CMS and UNOS, in order to fulfill their related but distinct functions, can appropriately and swiftly act to ensure that quality of care and patient safety is enhanced, as well as to ­make the system more accountable overall.

UNOS will undertake/propose the following action


UNOS has created a new public page on the OPTN website to increase transparency on MPSC performance improvement and compliance review activities. Work will continue to improve and expand this page, pending approvals from HRSA.


The OPTN will issue timely patient safety and improvement communications gleaned from current case reviews to inform the public, help members avoid safety events, and comply with OPTN obligations. Currently, HRSA must approve each communication.


This year, the OPTN MPSC will begin the process of enhancing its OPO performance measures to better hold OPOs accountable for their performance.

Advocate for increased coordination in system oversight by requiring CMS, HRSA and the OPTN to:


Share information on a consistent basis regarding performance trends, improvement, and compliance efforts.


Establish consistent protocols for escalating cases and conducting joint investigations between UNOS, CMS, and HRSA, especially as it relates to incidents, complaints, and trends in OPO and transplant program performance. Real‐time data will assist in ongoing reviews of OPOs and transplant hospitals.


Provide OPO and transplant programs education to improve understanding of both OPTN performance metrics and CMS regulations. This would require working with CMS to provide accurate and coordinated information and would assist OPOs and transplant programs in understanding the full scope of OPTN policies and CMS regulations.

UNOS published the Action Agenda on Jan. 30, 2023, to reflect the needs of the broader donation and transplant community. As we progress on the actions and recommendations outlined, we will post updates here accordingly.

All stakeholders, including UNOS, share a common mission:

Get as many usable transplant organs as possible to patients who need them, fairly, equitably and efficiently.

All parts of the national system must be held accountable for making sure that this happens. The OPTN contractor must provide the highest level of service to patients and the greatest level of transparency to the public who has charged it with this lifesaving work.

Up next:

8. Governance

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