OPTN/UNOS Public Comment Period- Liver Allocation

As you probably know, much is happening regarding liver allocation policy. The transplant community is at a crossroads with the OPTN/UNOS Liver and Intestinal Organ Allocation Committee’s recently released public comment proposal on enhancing liver allocation. I encourage all AST members to carefully review and comment on this proposal.

After carefully considering all the feedback received during the August 2016 public comment period that addressed geographic disparities in access to liver transplantation, the committee spent time considering potential alternative solutions and paths forward to address this issue. As part of this process, they took time to seek feedback and build consensus regarding recommendations for the committee in developing a new proposal, meeting with liver surgeons, physicians, and community stakeholders. The AST also participated in this Liver Panel discussion.

The new proposal aims to balance equity in access to liver transplants and recognize concerns that are raised regarding the impact of travel and logistics related to broader sharing. It moves away from the previously proposed eight districts model in favor of a geographic concentric circle model that is expected to increase sharing within the region (and sometimes outside of the region, depending upon the area covered by the circle) for candidates at a greater medical priority. The donor hospital will serve as the center point of this circle, and candidates listed at transplant programs within the circle will receive priority points. The proposal also includes a separate allocation classification for DCD donors and donors over the age of 70. The committee believes that these changes will enhance equity in access and organ utilization while limiting the impact on travel and logistics that was a concern in the first proposal.

This is clearly a challenging subject that requires thoughtful discussion. The AST is supportive of the process that UNOS has used and their engagement with the transplant community to get to this point.

As with all OPTN/UNOS public comment, the AST first seeks review and feedback from its Communities of Practice (COPs). While specific COPs are engaged to review proposals based upon their subject matter expertise, all COPs are welcome to review and provide feedback on any public comment proposal. This feedback is then reviewed by the Society’s Policy Committee, which works to craft a response on behalf of the AST for board review and approval. Our COPs are currently reviewing this proposal in addition to the other proposals currently out for comment. The Board looks forward to their thoughtful feedback.

HRSA has given a deadline to UNOS in which some agreement must be reached in working to resolve equity in allocation of livers. As we have all heard, the buzz regarding how to address this issue has already reached Washington, DC. If we as a community of transplant professionals cannot come to some agreement on this sensitive topic, we run the real risk of allocation decisions being made by Congress or the judicial system rather than by those who understand the medical and logistical nuances of organ transplantation.  As such, we believe it is of utmost importance for the transplant community to come to a viable consensus opinion.

I encourage all AST members to carefully review and comment on this proposal.  Though it may not be the ideal solution you might choose, we must recognize that intervention outside of OPTN/UNOS will reduce our rights to self-governance in an already highly regulated area of medicine. If you have constructive ideas for this issue, you can participate this the public comment here.

In addition, if you have thoughts on this that you would like to share with the AST leadership, feel free to post a comment in this blog.

To access the public comment, click here.



I am from a small rural county and I do not think it is fair to move livers away from this area and not consider the the low income minority patients in this area.

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