The American Hospital Association is urging CMS not to implement a proposed mandatory payment model meant to increase access to organ transplants, saying it is constructed in a way that may exacerbate inequalities and add "unnecessary disruption" to the transplant ecosystem.
In a July 16 letter to CMS Administrator Chiquita Brooks-LaSure, the AHA outlined what it called "problematic design elements" of the agency's proposed Increasing Organ Transplant Access Model, which was introduced in May with a tentative start date of Jan. 1. The model would test whether performance-based incentives would expand access to kidney transplants and reduce Medicare expenditures.
While it shares the IOTA's goal of increasing access, the AHA said it is concerned that the model's current emphasis on transplant volumes may "incentivize sub-par matches and exacerbate inequities."
The hospital industry's other key concerns are that the model would add "unnecessary disruption and uncertainty to the transplant ecosystem," as the government is undergoing a major overhaul of the Organ Procurement and Transplant Network. The AHA urged CMS not to move forward with the model in its current form, recommending the agency consider a voluntary payment model and revisit its proposals after changes under the OPTN modernization initiative are complete.
Patient advocacy groups have expressed mixed reactions to the proposed model, with some supporting the increased focus on expanding access and others sharing the AHA's concerns about potential negative effects on match quality and equity in transplant distribution.