Evaluation Plan
Evaluation Plan
Page 2 of 64
Policy 9.1.A: Adult Status 1A Requirements ..................................................................................... 23
Policy 9.1.B: Pediatric Status 1A Requirements................................................................................ 23
Policy 9.1.C: Pediatric Status 1B Requirements................................................................................ 24
Policy 9.2: Status and Laboratory Values Update Schedule .............................................................. 24
Policy 9.3.C: Specific MELD/PELD Exceptions ................................................................................. 25
Policy 9.3.F: Candidates with Hepatocellular Carcinoma (HCC) ........................................................ 25
Policy 9.3.G: MELD/PELD Score Exception Extensions .................................................................... 26
Policy 10.1.F: The LAS Calculation .................................................................................................. 26
Policy 10.1.G: Reporting Additional Data for Candidates with an LAS of 50 or Higher ........................ 27
Policy 10.2.B: Lung Candidates with Exceptional Cases ................................................................... 27
Policy 11.3.B: Kidney-Pancreas Waiting Time Criteria for Candidates At Least 18 Years Old ............. 28
Policy 13.2: Potential KPD Donor Requirements for Participation ...................................................... 28
Policy 13.11: Transportation of Kidneys ........................................................................................... 29
Policy 14.1.A: Living Donor Psychosocial Evaluation Requirements .................................................. 29
Policy 14.2.A: ILDA Requirements for Living Donor Recovery Hospitals ............................................ 30
Policy 14.2.B: ILDA Protocols for Living Donor Recovery Hospitals ................................................... 31
Policy 14.3: Informed Consent Requirements ................................................................................... 31
Policy 14.4.A: Living Donor Medical Evaluation Requirements .......................................................... 34
Policy 14.4.B: Additional Requirements for the Medical Evaluation of Living Kidney Donors ............... 36
Policy 14.4.C: Additional Requirements for the Medical Evaluation of Living Liver Donors .................. 37
Policy 14.5: Living Donor Blood Type Determination and Reporting .................................................. 38
Policy 14.5.A: Living Donor Blood Type Determination ..................................................................... 39
Policy 14.5.B: Living Donor Blood Subtype Determination................................................................. 39
Policy 14.5.C: Reporting of Living Donor Blood Type and Subtype .................................................... 39
Policy 14.7: Living Donor Pre-Recovery Verification ......................................................................... 40
Policy 15.1: Patient Safety Contact .................................................................................................. 41
Policy 15.3: Informed Consent of Transmissible Disease Risk........................................................... 41
Policy 15.4.A: Host OPO Requirements for Reporting Post-Procurement Donor Results and Discovery of
Potential Disease Transmissions ..................................................................................................... 41
Policy 16.5: Verification of Information before Shipping ..................................................................... 42
Policy 16.6.A: Deceased Donor Vessel Recovery and Transplant Use .............................................. 42
Policy 16.6.B: Vessel Storage .......................................................................................................... 43
Policy 18.1: Data Submission Requirements .................................................................................... 44
Policy 18.5.A: Reporting Requirements after Living Kidney Donation................................................. 45
Policy 18.5.B: Reporting Requirements after Living Liver Donation.................................................... 46
Bylaws Appendix B.1: OPO Compliance .......................................................................................... 47
Bylaws Appendix B.2: OPO Performance Requirements................................................................... 48
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Bylaws Appendix B.3: Quality Assessment and Performance Improvement (QAPI) Requirement ....... 49
Bylaws Appendix B.5: OPO Personnel ............................................................................................. 49
Bylaws Appendix C.5: Changes in Key Laboratory Personnel ........................................................... 50
Bylaws Appendix C.6.D: Regulatory Adverse Actions ....................................................................... 51
Bylaws Appendix D.1: Transplant Hospital Compliance .................................................................... 52
Bylaws Appendix D.3: Quality Assessment and Performance Improvement (QAPI) Requirement ....... 52
Bylaws Appendix D.6: Transplant Program Key Personnel ............................................................... 53
Bylaws Appendix D.6.B: Surgeon and Physician Coverage (Program Coverage Plan) ....................... 53
Bylaws Appendix D.7: Changes in Key Transplant Program Personnel ............................................. 54
Bylaws Appendix D.7.D: Reinstatement of Previously Designated Primary Surgeon or Primary Physician
...................................................................................................................................................... 55
Bylaws Appendix D.10: Review of Transplant Program Functional Activity ........................................ 56
Bylaws Appendix D.11.A: Transplant Program Performance ............................................................. 57
Bylaws Appendix D.11.B: Patient Notification Requirements for Waiting List Inactivation.................... 58
Bylaws Appendix F.6.E: Conditional Program Approval Status .......................................................... 59
Bylaws Appendix K.1.A: Program Component Cessation .................................................................. 60
Bylaws Appendix K.3.A: Notice to the OPTN Contractor of Long-term Inactive Status ........................ 60
Bylaws Appendix K.3.B: Notice to the Patients of Long-term Inactive Status ...................................... 61
Bylaws Appendix K.4.A: Notice to the OPTN Contractor ................................................................... 62
Bylaws Appendix K.4.B: Notice to the Patients ................................................................................. 62
Bylaws Appendix K.5: Transition Plan during Long-term Inactivity, Termination, or Withdrawal........... 63
Bylaws Appendix K.6: Transferred Candidates Waiting Time ............................................................ 64
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OPTN Member Evaluation Plan Introduction
OPTN members agree to comply with OPTN obligations, which are set forth in the National Organ Transplant
Act, as amended, 42 U.S.C. 273 et seq., the OPTN Final Rule, 42 CFR Part 121, OPTN bylaws, and OPTN
policies. The OPTN Member Evaluation Plan is provided as guidance for members on how UNOS, as the
OPTN contractor, conducts its routine reviews and evaluations of members for compliance with OPTN
obligations.
Members are expected to comply with all obligations, regardless of whether an obligation is specifically
described in the OPTN Member Evaluation Plan as one that is routinely monitored. Reports of non-
compliance with any OPTN obligation will be investigated by UNOS.
Routine review and evaluation activities performed by UNOS include:
1. Reviewing applications submitted for OPTN membership and designation as an organ-specific
transplant program and/or living donor recovery hospital
2. Reviewing applications for mandatory key personnel for maintenance of organ-specific transplant
program and/or living donor recovery hospital designation
3. Monitoring member actions associated with transplant program inactivation or re-activation, and
requests for withdrawal from the OPTN
4. Monitoring member transplant program and OPO performance-related data including graft and patient
survival rates, organ procurement rates and transplant rates
5. On-site surveys of individual member compliance with OPTN obligations
6. Reviewing all deceased donor match runs that result in a transplanted organ to ensure that allocation
was carried out according to OPTN policy, and investigating potential policy violations, including when:
a. An organ is accepted for one candidate, but another candidate is transplanted
b. Candidates on a match run are skipped or bypassed in order to allocate the organ to a candidate
further down the match run
c. An organ is transplanted into an individual who did not appear on the match run
d. An organ is exported to a foreign country prior to exhausting the match run
e. A 0-ABDR mismatch kidney is not offered to the appropriate number of 0-ABDR mismatch
candidates prior to allocating to non-0-ABDR mismatch candidates
f. Double kidneys are allocated from a donor who did not meet double kidney criteria
g. An organ is allocated from a match run using a negative or pending hepatitis B or hepatitis C (or
CMV for intestine) test result that is later reported as positive
7. Investigating issues reported to UNOS or discovered during routine reviews of OPTN members,
including:
a. Potential patient safety events
b. Potential donor-derived disease transmission events
c. Living donor adverse events
d. Vessels recovered from a living donor or a donor positive for hepatitis B or hepatitis C that were
transplanted into someone other than the recipient of that donors organ
e. Complaints
f. Reports or allegations of potential member noncompliance with OPTN obligations
For more information on OPTN member requirements and obligations, see:
National Organ Transplant Act, as amended, 42 U.S.C. 273 et seq.
OPTN Final Rule, 42 CFR Part 121
Article I: Membership of the OPTN bylaws
Appendix D of the OPTN bylaws
Appendix L of the OPTN bylaws
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Policy 2.2: OPO Responsibilities
Effective Date: 2/1/2014
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Policy 2.4: Deceased Donor Medical and Behavioral History
Effective Date: 9/1/2014
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Policy 2.6: Deceased Donor Blood Type Determination and Reporting
Effective Date: 6/23/2016
Additional Guidance:
A hospital's electronic medical record (EMR) can be a source document for lab results when the performing
lab's results are directly uploaded into the EMR.
Review a sample of deceased donor records when subtype is reported, to verify that:
There are identical results for two separate blood subtyping tests
Tests were completed on two separate blood samples
The draw times for the samples used for the two tests are at different times
Samples used were pre-red blood cell transfusion
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Policy 2.8: Required Deceased Donor General Risk Assessment
Effective Date: 9/1/2014
Additional Resources:
FDA-approved screening and diagnostic tests: http://tinyurl.com/FDA-SCREENING
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Policy 2.11.B: Required Information for Deceased Liver Donors
Effective Date: 9/1/2014
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Policy 2.11.E: Required Information for Deceased Pancreas Donors
Effective Date: 9/29/2016
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Policy 2.15.B: Pre-Recovery Verification
Effective Date: 6/23/2016
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Policy 3.2: Notifying Patients of Their Options
Effective Date: 2/1/2014
Additional Guidance:
A hospital's electronic medical record (EMR) can be a source document for lab results when the performing
lab's results are directly uploaded into the EMR.
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Policy 3.4.D: Candidate Human Leukocyte Antigen (HLA) Requirements
Effective Date: 9/1/2016
Additional Resources:
Patient Information Letter: http://optn.transplant.hrsa.gov/resources/informing-patients
Page 14 of 64
Policy 3.6.C: Individual Waiting Time Transfers
Effective Date: 9/1/2015
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Policy 5.3.C: Informed Consent for Kidneys Based on KDPI Greater than
85%
Effective Date: 9/1/2016
Additional Guidance:
Additional consent is not required to receive offers of kidneys with a KDPI greater than 85% for candidates who
were registered on the kidney waiting list before December 4, 2014 and were consented to receive an ECD
kidney
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Policy 5.8: Pre-Transplant Verification
Effective Date: 6/23/2016
Page 17 of 64
Additional Guidance:
For purposes of this policy, a living donor organ is not considered "received" until it has been recovered.
Additional Guidance:
For purposes of this policy, a living donor organ is not considered "received" until it has been recovered.
Page 18 of 64
Policy 6.1.A: Adult Heart Status 1A Requirements
Effective Date: 2/1/2014
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Policy 6.2: Status Updates
Effective Date: 2/1/2014
Additional Guidance:
A hospital may use discretion in defining the start date of regularly administered dialysis for ESRD as long as
there is documentation (i.e., 2728 form, physician's note, dialysis center documentation) of the date entered.
The dialysis start date from the CMS database, if displayed in UNet, may be used as documentation
supporting the start date of regularly administered dialysis for ESRD entered by the hospital. The hospital is
not required to print out the information from UNet.
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Policy 8.4.B: Waiting Time for Candidates Registered prior to Age 18
Effective Date: 12/4/2014
Additional Guidance:
A hospital may use discretion in defining the start date of regularly administered dialysis for ESRD as long as
there is documentation (i.e., 2728 form, physician's note, dialysis center documentation) of the date entered.
The dialysis start date from the CMS database, if displayed in UNet, may be used as documentation
supporting the start date of regularly administered dialysis for ESRD entered by the hospital. The hospital is
not required to print out the information from UNet.
Additional Guidance:
A hospital may use discretion in defining the start date of regularly administered dialysis for ESRD as long as
there is documentation (i.e., 2728 form, physician's note, dialysis center documentation) of the date entered.
The dialysis start date from the CMS database, if displayed in UNet, may be used as documentation
supporting the start date of regularly administered dialysis for ESRD entered by the hospital. The hospital is
not required to print out the information from UNet.
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Policy 8.5.D: Allocation of Kidneys by Blood Type
Effective Date: 9/1/2016
Additional Guidance:
The written approval in the candidate's medical record must occur on the same date or on an earlier date than
the approval is documented in UNet.
Written approval may be in the form of a physical or electronic signature. The hospital's internal policies
regarding requirements for electronic signatures apply. Entry in UNet does not qualify as an electronic
signature.
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Policy 9.1.A: Adult Status 1A Requirements
Effective Date: 9/1/2015
Page 23 of 64
Policy 9.1.C: Pediatric Status 1B Requirements
Effective Date: 9/1/2015
Page 24 of 64
Policy 9.3.C: Specific MELD/PELD Exceptions
Effective Date: 9/1/2015
Page 25 of 64
Policy 9.3.G: MELD/PELD Score Exception Extensions
Effective Date: 9/1/2015
Page 26 of 64
Policy 10.1.G: Reporting Additional Data for Candidates with an LAS of 50
or Higher
Effective Date: 2/1/2015
Additional Guidance:
A transplant program is only required to report an updated PCO2 type and value if the test was performed
within the previous 14 days.
Page 27 of 64
Policy 11.3.B: Kidney-Pancreas Waiting Time Criteria for Candidates At
Least 18 Years Old
Effective Date: 9/1/2015
Additional Guidance:
A hospital may use discretion in defining the start date of regularly administered dialysis for ESRD as long as
there is documentation (i.e., 2728 form, physician's note, dialysis center documentation) of the date entered.
The dialysis start date from the CMS database, if displayed in UNet, may be used as documentation
supporting the start date of regularly administered dialysis for ESRD entered by the hospital. The hospital is
not required to print out the information from UNet.
Page 28 of 64
Policy 13.11: Transportation of Kidneys
Effective Date: 2/1/2014
Page 29 of 64
Recovery hospitals will provide:
The requested sample of living donor records
The recovery hospital's internal policies, procedures and protocols for the care of living donors
Evidence as needed to verify compliance
Access to relevant staff who can answer interview questions
Additional Guidance:
Site surveyors will examine the hospital's internal policies, procedures and/or protocols to verify the presence
of a process by which the hospital ensures that the assigned ILDA for a given potential living donor patient is
not involved in the evaluation of the associated transplant candidate, and is not involved in the decision to
proceed to transplantation or approve the transplant candidate for transplantation.
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Policy 14.2.B: ILDA Protocols for Living Donor Recovery Hospitals
Effective Date: 2/1/2015
Page 31 of 64
A deceased donor organ might become available for the recipient before the donor evaluation is
completed or the living donor transplant occurs
Any transplant candidate might have risk factors for increased morbidity or mortality that are not
disclosed to the donor
The health information obtained during the evaluation will be subject to the same regulations as all
medical records
The medical evaluation could reveal conditions that must be reported to local, state or federal public
health authorities
The recovery hospital is required to report living donor follow-up information at six months, one year,
and two years post-donation
Any infectious disease or malignancy pertinent to acute recipient care discovered during the first two
years of the donor's post-operative follow-up care:
o May need to be reported to local, state or federal public health authorities
o Will be disclosed to their recipients transplant center
o Will be reported through the OPTN Improving Patient Safety Portal
The donor will receive a medical evaluation
The donor will receive a psychosocial evaluation
The hospital may refuse the donor
The following are inherent risks associated with evaluation for living donation:
o Allergic reactions to contrast
o Discovery of reportable infections
o Discovery of serious medical conditions
o Discovery of adverse genetic findings
o Discovery of abnormalities that may require additional testing at the donor's expense or create
the need for unexpected decisions by the transplant team
Review a sample of living donor medical records, and any material incorporated into the medical record by
reference, for documentation that the recovery hospital provided information or disclosure to the donor
addressing the risk of the following:
Death
Scars, hernia, wound infection, blood clots, pneumonia, nerve injury, pain, fatigue, and other
consequences typical of any surgical procedure
Abdominal symptoms such as bloating, nausea, and bowel obstruction
The morbidity and mortality of the donor may be impacted by obesity, hypertension, or other donor-
specific pre-existing conditions
Problems with body image
Post-surgery depression or anxiety
Feelings of emotional distress or grief if the transplant recipient experiences any recurrent disease or if
the recipient dies
Changes to the donor's lifestyle from donation
Personal expenses of travel, housing, child care costs, and lost wages related to donation might not be
reimbursed
Need for life-long follow-up at the donor's expense
Loss of employment or income
Negative impact on the ability to obtain future employment
Negative impact on the ability to obtain, maintain, or afford health, disability, and life insurance
Future health problems experienced by living donors following donation may not be covered by the
recipient's insurance
Risks may be temporary or permanent
Risks may include those listed, but are not limited to those listed
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Review a sample of living donor medical records, and any material incorporated into the medical record by
reference, for documentation that the recovery hospital provided the following information to the donor
regarding outcome and survival data:
When the recipient transplant hospital is known (or is the same as the recovery hospital):
o SRTR's national 1-year patient and transplanted organ survival rates for the organ being
transplanted
o SRTR's most recent hospital-specific 1-year patient and transplanted organ survival rates for the
recipient's transplant hospital for the organ being transplanted
Review a sample of living donor medical records, and any material incorporated into the medical record by
reference, for documentation that the recovery hospital provided additional information or disclosure specific to
the living kidney donor regarding:
Education about expected post-donation kidney function and the potential impact on chronic kidney
disease (CKD) and end-stage renal disease (ESRD) on the living kidney donor in the future, including:
o On average, donors may have a 25-35% permanent loss of kidney function after donation
o Baseline risk of ESRD for living kidney donors does not exceed that of members of the general
population with the same demographic profile
o Living donor risks must be interpreted in light of the known epidemiology of both CKD and
ESRD. When CKD or ESRD occurs, CKD generally develops in mid-life (40-50 years old) and
ESRD generally develops after age 60
o The medical evaluation of a young donor cannot predict lifetime risk of CKD or ESRD
o Living donors may be at a higher risk for CKD if they sustain damage to the remaining kidney
o The development of CKD and subsequent progression to ESRD may be more rapid with only
one kidney
o Dialysis is required if the donor develops ESRD
o Current practice is to prioritize prior living kidney donors who become kidney transplant
candidates according to OPTN policy
Potential medical or surgical risks
o Decreased kidney function
o Kidney failure and the need for dialysis or kidney transplant for the donor
o Risks may be temporary or permanent
o Risks may include those listed, but are not limited to those listed
Review a sample of living donor medical records, and any material incorporated into the medical record by
reference, for documentation that the recovery hospital provided additional information or disclosure specific to
the living liver donor regarding:
Potential medical or surgical risks
o Acute liver failure with need for liver transplant
o Transient liver dysfunction with recovery
o Risk of red cell transfusions or other blood product transfusions
o Biliary complications, including leak or stricture, that may require additional intervention
o Post-donation laboratory tests may result in abnormal or false positive results that may trigger
additional tests that have associated risks
Living liver donor recipient outcome and survival data when the recipient transplant hospital is known
(or is the same as the recovery hospital):
o SRTR's most recent hospital-specific 1-year living donor recipient survival and living donor graft
survival rates for the recipient's transplant hospital
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Recovery hospitals will provide:
The requested sample of living donor records
The recovery hospital's internal policies, procedures and protocols for the care of living donors
Evidence as needed to verify compliance
Access to relevant staff who can answer interview questions
Page 34 of 64
Psychiatric illness
Depression
Suicide attempts
Increased risk behavior as defined by the U.S. PHS Guideline
Review a sample of living donor medical records, and any material incorporated into the medical record by
reference, for documentation that there are results for:
Height
Weight
BMI
Vital signs
A review of major organ systems
Complete Blood Count (CBC) with platelet count
Blood type (and subtype if tested)
Prothrombin Time (PT) or International Normalized Ratio (INR)
Partial Thromboplastin Time (PTT)
Metabolic testing, including:
o Electrolytes
o BUN
o Creatinine
o Albumin
o Calcium
o Phosphorus
HCG quantitative pregnancy test (for premenopausal women without surgical sterilization)
Chest X-ray
Electrocardiogram (ECG)
CMV (Cytomegalovirus) antibody testing
EBV (Epstein Barr Virus) antibody testing
Syphilis testing
Infectious disease testing performed no earlier than 28 days before organ recovery:
o HIV antibody (anti-HIV) testing or HIV antigen/antibody (Ag/Ab) combination test
o Hepatitis B surface antigen (HBsAg) testing
o Hepatitis B core antibody (anti-HBc) testing
o Hepatitis C antibody (anti-HCV) testing
o Hepatitis C ribonucleic acid (RNA) by nucleic acid test (NAT)
Additional infectious disease testing for any living donor identified as increased risk according to the
U.S. PHS Guideline criteria (except donors whose only increased risk factor is receiving hemodialysis
within the preceding 12 months) using either:
o HIV RNA by NAT
o HIV Ag/Ab combination test
Review the hospitals internal policies, procedures and/or protocols to verify that the hospital has developed
and implemented written protocols that address:
Identifying and testing donors at risk for transmissible seasonal or geographically defined endemic
disease
Cancer screening for:
o Cervical cancer
o Breast cancer
o Prostate cancer
o Colon cancer
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o Lung cancer
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HDL Cholesterol
LDL Cholesterol
o Glucose tolerance test or glycosylated hemoglobin, if indicated (in first degree relatives of
diabetics and in high risk individuals)
Urinalysis or urine microscopy
Measurement of urinary protein and albumin excretion
Measurement of glomerular filtration rate (GFR) by isotopic methods or a creatinine clearance
calculated from a 24-hour urine collection
24-hour urine stone panel (if indicated according to policy)
Review the hospitals internal policies, procedures and/or protocols to verify that the hospital has developed
and implemented written protocols that address:
PKD screening
Page 37 of 64
Testing for genetic diseases
Screening for autoimmune disease
Pre-donation liver biopsy
Additional Guidance:
A hospital's electronic medical record (EMR) can be a source document for lab results when the performing
lab's results are directly uploaded into the EMR.
Page 38 of 64
Policy 14.5.A: Living Donor Blood Type Determination
Effective Date: 6/23/2016
Page 39 of 64
Policy 14.7: Living Donor Pre-Recovery Verification
Effective Date: 6/23/2016
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Policy 15.1: Patient Safety Contact
Effective Date: 9/1/2015
Page 41 of 64
OPOs will provide:
The requested sample of deceased donor medical records
Additional Guidance:
All vessels shared between hospitals must be reported, even if they are not used.
The receiving transplant hospital is not required to report vessels as shared when it receives vessels directly
from the recovering OPO.
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Policy 16.6.B: Vessel Storage
Effective Date: 6/23/2016
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Policy 18.1: Data Submission Requirements
Effective Date: 4/14/2016
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Additional Guidance:
When calculating the due date for deceased donor feedback forms, the procurement date is defined as the
date the donor entered the operating room for purposes of organ recovery
Page 45 of 64
Policy 18.5.B: Reporting Requirements after Living Liver Donation
Effective Date: 3/31/2015
Page 46 of 64
Bylaws Appendix B.1: OPO Compliance
Effective Date: 9/1/2012
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The OPTN contractor learns of a final adverse action taken by a regulatory agency against an OPO
which was not reported to the OPTN contractor in writing as defined in the bylaws
OPOs must:
Notify the OPTN contractor when any regulatory agency takes action against the OPO. Notification must:
Be in writing
Be received by the OPTN contractor within 10 business days after the OPO receives notification of the
final adverse action
Include all documents relating to the final adverse action
Definitions:
Final adverse actions by an agency include, but are not limited to, any of the following:
Decertification by the Center for Medicare and Medicaid Services (CMS)
Any action by a state licensing authority that affects the organization's ability to function
Any action by the state health department that affects the organization's ability to function
Loss of accreditation by the Association of Organ Procurement Organizations (AOPO), American
Association of Tissue Banks (AATB), or Joint Commission on Accreditation of Healthcare Organizations
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Bylaws Appendix B.2: OPO Performance Requirements
Effective Date: 9/1/2012
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
An OPO meets or falls below all of the following thresholds for a single organ or all organs taken
together:
o Expected organ yield per 100 donors observed organ yield per 100 donors > 10
o Ratio of observed to expected yield < 0.90
o Twosided pvalue less than 0.05
An OPO is noncompliant with MPSC requests or fails to adopt and implement a plan for improvement
The MPSC will review blinded data derived from UNet to:
Identify whether observed organ yields fall below the expected yield, given individual OPO donor
characteristics
Evaluate overall (or aggregate) organ yield
Evaluate organ-specific yields
Staff will send inquiries on behalf of the MPSC:
When an OPO is identified as having experienced lower than expected yields during a specified 2.5
year cohort
That may include a request for continued reporting until observed organ yields improve
That may include a requirement for the OPO to promptly adopt and implement a plan for improvement
That may lead to consideration for adverse action, if the OPO does not comply
MPSC monitoring may include:
A request for continued reporting until observed organ yields improve
A requirement for the OPO to promptly adopt and implement a plan for improvement
OPOs must:
Cooperate with the performance review process if yields meet or fall below thresholds. This may include:
Responding to inquiries regarding performance
Complying with MPSC recommendations regarding performance
Participating in an informal discussion regarding a performance review
Participating in a peer visit to identify opportunities for improvement
Formulating a plan for quality improvement
Page 48 of 64
Bylaws Appendix B.3: Quality Assessment and Performance Improvement
(QAPI) Requirement
Effective Date: 9/1/2015
How the OPTN contractor will evaluate member compliance with this bylaw:
MPSC monitoring may include:
Review of an OPOs QAPI program, including documentation that all elements of the program have
been implemented
Additional Guidance:
This QAPI requirement will not be routinely monitored by the OPTN Contractor through site survey or other
means. The MPSC may request information about an OPO's QAPI program in instances where the MPSC has
a serious concern about the OPO's ability to independently improve and maintain compliance with OPTN
obligations, such as repeated violations of the same or similar policies or prolonged periods of
underperformance.
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
A member fails to inform the OPTN contractor of a change in key personnel within 30 days of departure
A member fails to submit the replacement's name and curriculum vitae no less than 30 days before the
change will take effect
OPOs must:
Submit written notice immediately (and within 30 days) after learning that the OPO administrative director or
medical director plans to leave or otherwise change positions and no longer serve in one of these roles.
Written notice of a change in key personnel must include:
Name of new director
Status of appointment (interim or permanent)
Effective date of the change
A current curriculum vitae
Notify the OPTN contractor if it has not filled a vacant administrative or medical director position permanently
within six months. The notification must include the steps taken to fill the position and the timeline for
completing the hiring process.
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Bylaws Appendix C.5: Changes in Key Laboratory Personnel
Effective Date: 2/1/2014
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
A member fails to inform the OPTN contractor of a change in key personnel within seven business days
of laboratory knowledge of the departure or extended absence
A member fails to submit a completed personnel change application in the time and manner required
A member fails to submit an updated laboratory coverage plan in the time and manner required
Definitions:
Changes in laboratory key personnel:
A change in key personnel occurs when an individual in a key personnel role:
Departs
Is unavailable to perform responsibilities for more than 30 days (temporary basis)
Changes position so that he/she no longer serves in a key personnel role
Accepts additional responsibilities for more than 30 days at another histocompatibility laboratory
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Bylaws Appendix C.6.D: Regulatory Adverse Actions
Effective Date: 2/1/2014
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The OPTN contractor learns of a final adverse action taken by a regulatory agency against a
histocompatibility laboratory, and the histocompatibility laboratory did not report this action to the OPTN
contractor as defined in the bylaws
Definitions:
Final adverse actions by an agency include, but are not limited to, any of the following:
Decertification by the Center for Medicare and Medicaid Services (CMS)
Any action by a state licensing authority that affects the organization's ability to function
Any action by the state health department that affects the organization's ability to function
Loss of accreditation by the Association of Organ Procurement Organizations (AOPO), American
Association of Tissue Banks (AATB), or Joint Commission on Accreditation of Healthcare Organizations
Page 51 of 64
Bylaws Appendix D.1: Transplant Hospital Compliance
Effective Date: 9/1/2012
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The OPTN contractor learns of a final adverse action taken by a regulatory agency against a transplant
hospital, and the transplant hospital did not report this action to the OPTN contractor as defined in the
bylaws
Definitions:
Final adverse actions by an agency include, but are not limited to, any of the following:
Decertification by the Center for Medicare and Medicaid Services (CMS)
Any action by a state licensing authority that affects the organization's ability to function
Any action by the state health department that affects the organization's ability to function
Loss of accreditation by the Association of Organ Procurement Organizations (AOPO), American
Association of Tissue Banks (AATB), or Joint Commission on Accreditation of Healthcare Organizations
How the OPTN contractor will evaluate member compliance with this bylaw:
MPSC monitoring may include:
Review of a transplant hospitals QAPI program, including documentation that all elements of the
program have been implemented
Additional Guidance:
This QAPI requirement will not be routinely monitored by the OPTN Contractor through site survey or other
means. The MPSC may request information about a transplant hospital's QAPI program in instances where the
MPSC has a serious concern about the hospital's ability to independently improve and maintain compliance
with OPTN obligations, such as repeated violations of the same or similar policies or prolonged periods of
underperformance.
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Bylaws Appendix D.6: Transplant Program Key Personnel
Effective Date: 9/1/2015
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The OPTN contractor learns of an active and approved transplant program performing organ
transplants without having both a qualified primary surgeon and a qualified primary physician for the
organ type in question
Additional Resources:
Membership Application Forms: http://www.unos.org/donation/index.php?topic=application
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will review materials submitted by members, including coverage plans. Coverage plans
will be:
Reviewed by an adhoc committee of the MPSC when submitted with an application
Reviewed by the MPSC when requested
Reviewed by an MPSC subcommittee when requested
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Notify candidates when:
There are significant program or personnel changes, including:
o Change in primary transplant physician or surgeon
o Becoming a single surgeon or single physician program
o Previously being a single surgeon or single physician program and now are able to again
provide 365/24/7 coverage
o Any other major or substantial programmatic changes that the program feels will impact or alter
patients' ability to receive transplant services
Inform patients, if staffed by a single surgeon or physician, that:
The individual may not be available to the program at all times
The individual's unavailability may impact patient care, including the programs ability to:
o Accept organ offers
o Procure organs
o Perform transplants
Address each of the following requirements in the program coverage plan:
The program's ability to have at least one transplant surgeon and transplant physician available 365
days a year, 24 hours a day, 7 days a week
The program provides candidates with a written summary of the program coverage plan
o When the candidates are listed
o When there are significant or substantial program or key personnel changes
That the transplant surgeons and transplant physicians on call for the program cannot be
simultaneously on call for another hospital's transplant program that is more than 30 miles away
(unless the circumstances have been reviewed and approved by the MPSC)
That a transplant surgeon or transplant physician is readily available in a timely manner to:
o Facilitate organ acceptance
o Facilitate organ procurement
o Facilitate organ transplantation
o Address urgent patient issues
That the primary transplant surgeon and primary transplant physician are not designated as the primary
transplant physician or surgeon at another transplant hospital unless both hospitals have additional
transplant surgeons and physicians for those programs
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
A member fails to inform the OPTN contractor of a change in key personnel within seven business days
of transplant program knowledge of the departure or extended absence
A member fails to submit a completed personnel change application in the time and manner required
A member fails to submit a written notification that the program plans to inactivate or withdraw
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Transplant hospitals must:
Notify the OPTN contractor in writing of a change in key personnel within seven business days of transplant
program knowledge of the departure or extended absence of the program's primary surgeon or physician
(including primary living donor surgeons).
Submit a completed personnel change application any time they wish to designate a new primary physician or
surgeon. The completed application must:
Demonstrate that the proposed surgeon or physician meets the primary surgeon or physician
requirements for that organ
Be received by the OPTN contractor at least 30 days before the effective date of the change in key
personnel (due date will be provided by staff)
If the program received less than 60 days advance notice of a primary physician or surgeon's departure or
need for temporary leave, the application must be submitted to the OPTN contractor within 30 days after
the program notifies the OPTN contractor of the pending change (due date will be provided by staff)
Voluntarily inactivate or withdraw its designated transplant program status, if:
The transplant program's primary surgeon or physician ends active involvement with the program on a
permanent or temporary basis, and
The program is unable to:
o Submit a completed key personnel application by the due date
o Demonstrate in the application that the proposed replacement meets the primary surgeon or
physician requirements
Additional Resources:
Membership Application Forms: http://www.unos.org/donation/index.php?topic=application
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will review written reinstatement requests.
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Bylaws Appendix D.10: Review of Transplant Program Functional Activity
Effective Date: 9/1/2015
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The program has been identified as functionally inactive because it has not performed a transplant
during a defined period. The relevant time periods are
o Kidney, liver or heart: 3 consecutive months
o Pancreas or lung: 6 consecutive months
o Stand-alone pediatric programs: 12 consecutive months
The member does not respond to MPSC inquiries regarding functional inactivity
Additional Guidance:
Programs will not be identified for functional inactivity and referred to the MPSC during the first year after
approval or reactivation of the program.
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Bylaws Appendix D.11.A: Transplant Program Performance
Effective Date: 9/1/2015
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The member falls below the established thresholds for review of post-transplant patient or graft survival
The member does not respond to MPSC inquiries regarding lower than expected outcomes
The member fails to promptly adopt and implement a plan for quality improvement
The member fails to inactivate a program or a component of a program or withdraw designated
transplant program status when recommended by the MPSC
The MPSC will review blinded data derived from UNet to:
Identify transplant programs for review that have performed 10 or more transplants within 2.5 years and
meet either of the following criteria:
o A probability greater than 75% that the hazard ratio is greater than 1.2
o A probability greater than 10% that the hazard ratio is greater than 2.5
Identify transplant programs for review that have performed nine or fewer transplants within 2.5 years
and have:
o At least one event in a 2.5-year cohort
o At least one event in subsequent years
Staff will send inquiries on behalf of the MPSC:
To programs identified as having experienced lower than expected outcomes during a specified 2.5-
year cohort
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Bylaws Appendix D.11.B: Patient Notification Requirements for Waiting List
Inactivation
Effective Date: 9/1/2015
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The member fails to notify the patients in the time and manner required
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Bylaws Appendix F.6.E: Conditional Program Approval Status
Effective Date: 9/1/2012
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will review materials submitted by members:
The progress of each program toward meeting the requirements for full approval
A report provided by the transplant program before the end of the first year of conditional approval
A final report before the end of the approval period, which must document the member's ability to meet
the requirements for full approval
Key personnel change applications proposing a new surgeon that fully meets the primary living donor
liver surgeon criteria if the second surgeon does not meet criteria at the end of the conditional approval
Definitions:
Interim operating procedures may be required by the MPSC, and may include:
Submission of reports describing the surgeon's progress towards meeting the requirements
Other operating conditions to demonstrate ongoing quality and efficient patient care
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Bylaws Appendix K.1.A: Program Component Cessation
Effective Date: 9/1/2012
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will review patient notification letters and refer the matter to the MPSC for consideration
when:
The OPTN contractor is notified of transplant program cessation
Transplant program component cessation notifications do not meet bylaw requirements
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will review materials submitted by members:
Written notice to the OPTN contractor of inactivation
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Bylaws Appendix K.3.B: Notice to the Patients of Long-term Inactive Status
Effective Date: 9/1/2015
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The member fails to submit the required information in the time and manner required
The member fails to notify the patients in the time and manner required
The OPTN contractor will review materials submitted by members:
Draft copies of patient notification letters
Additional Guidance:
If a natural disaster adversely affects the function of a transplant program, the patient notification requirements
will be applied reasonably and flexibly.
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Bylaws Appendix K.4.A: Notice to the OPTN Contractor
Effective Date: 9/1/2012
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will review materials submitted by members:
Written notice of withdrawal
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
The member fails to submit the required information in the time and manner required
The member fails to notify the patients in the time and manner required
The OPTN contractor will review materials submitted by members:
Draft copies of patient notification letters
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Bylaws Appendix K.5: Transition Plan during Long-term Inactivity,
Termination, or Withdrawal
Effective Date: 9/1/2012
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate any allegations of noncompliance
The OPTN contractor will review materials submitted by members:
Transition plans
Routine reports
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Bylaws Appendix K.6: Transferred Candidates Waiting Time
Effective Date: 9/1/2015
How the OPTN contractor will evaluate member compliance with this bylaw:
The OPTN contractor will investigate and refer a member to the MPSC for review when:
No written progress report is received within 90 days after the actual patient transfer date
It appears that the member has not complied with their submitted plan
The OPTN has requested, but not received, an updated progress report
The OPTN contractor will review materials submitted by members:
The written collective patient transfer agreement and plan submitted by the transplant programs to
confirm that it contains all required elements
Progress reports submitted by the accepting transplant program to confirm that the program is
complying with the submitted plan
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