CMS issues final rule for mandatory organ transplant payment model

The Centers for Medicare & Medicaid Services Nov. 26 released a final rule for the Increasing Organ Transplant Access Model. This new mandatory payment model will test whether performance-based incentives or penalties for participating transplant hospitals will increase access to kidney transplants for patients with end-stage renal disease while preserving or enhancing quality of care, improving equitable access to kidney transplant care and reducing Medicare expenditures. The model will run for six years. Participation will be mandatory for all eligible hospitals (i.e. nonpediatric kidney transplant hospitals meeting minimum volume thresholds) located within half of the nation’s donation service areas. CMS posted a list of the 103 hospitals required to participate on their website.

In response to stakeholder feedback, including concerns raised by the AHA, the agency made some adjustments to the model. These adjustments include delaying the start date to July 1, 2025, increasing the maximum upside payment from $8,000 to $15,000 per case, adjusting transplant targets to reflect the average number of deceased or living transplants during baseline years (versus the highest count as proposed), and removing three quality measures. The agency also did not finalize transparency requirements, which would have required IOTA participants to inform beneficiaries of the number of times an organ is declined on the Medicare beneficiary’s behalf and the reason(s) for the decline.

AHA will provide additional details about the IOTA final rule in a Special Bulletin.