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The AST is committed to keeping members informed about the federal policy issues shaping transplantation and the advocacy efforts underway on behalf of our community.
We would like to thank the members who have reached out following our first Advocacy Brief to share comments, questions, and ideas. We appreciate hearing from you and encourage all AST members to reach out at any time. Your perspectives help us better understand the issues that are most important to our members and shape the Society’s advocacy priorities and efforts.
Advocacy & Policy 101: How AST Turns Member Expertise into Action
Advocacy is rarely a single action or a quick process. Changes to federal law and policy often require sustained engagement over months or years, and the AST is one of many stakeholders working to inform decisions made by Congress and federal agencies.
Depending on the issue, the AST may submit formal comments on proposed regulations, provide clinical and scientific expertise, work with coalition partners, or communicate directly with congressional offices and federal agencies. Furthermore, the AST helps inform the transplant community about significant issues and opportunities for feedback, enabling members to connect with their political leaders and provide individual public comments. These efforts give the transplant community a voice in the policymaking process, but the ultimate decisions rest with Congress and federal agencies.
Public engagement can meaningfully inform this process. Congressional offices rely on constituent input to understand priorities and the real-world effects of policy, while federal agencies consider substantive public comments when developing final regulations. For this reason, timely, informed participation by transplant professionals and patients helps ensure that the clinical and practical realities of transplantation are represented in policy discussions. That is why continued engagement matters. Even when an advocacy effort does not result in an immediate policy change, it can help educate policymakers, build support and relationships, identify unintended consequences, and create opportunities for future progress.
Member input is an important part of that process. AST members bring firsthand clinical, scientific, and patient-care experience that helps identify emerging policy challenges and demonstrate how federal policies affect transplantation in practice. Your engagement helps strengthen the AST’s advocacy by ensuring that policymakers hear directly from the professionals working in the field and that our priorities reflect the needs of the broader transplant community. We encourage you to continue sharing the policy challenges, ideas, and emerging issues you believe the AST should be aware of.
Congressional Update
Congress Begins August Recess as Government Funding Deadline Approaches
The House and Senate are currently in recess for the month of August. The House is scheduled to return to Washington on August 31, while the Senate is scheduled to return on September 14.
Before departing Washington, the Senate passed a continuing resolution (CR) that would keep the federal government funded through mid-December. The House will need to pass the CR after returning to Washington to avoid a government shutdown when current funding expires at the end of September.
The CR would also delay implementation of the Office of Management and Budget's proposed rule, "Regulation for Federal Financial Assistance," until at least mid-December.
As shared in our previous Advocacy Brief, the AST submitted comments on the proposed rule outlining its potential impact on the transplant research community and advocated for policies that continue to support scientific innovation and federally funded research.
Living Donor Protection Act Continues to Advance
The Living Donor Protection Act (LDPA) continues to move through the Senate after advancing through the Senate Health, Education, Labor, and Pensions (HELP) Committee earlier this year.
The AST has been in communication with the bill sponsors, who remain committed to advancing the legislation in the Senate. The Society will continue to monitor the legislation and advocate for policies that protect and support living organ donors.
HHS Update
HHS Announces Action to Decertify Kentucky Organ Procurement Organization
U.S. Department of Health and Human Services Secretary Robert F. Kennedy Jr., Centers for Medicare & Medicaid Services Administrator Dr. Mehmet Oz, and Health Resources and Services Administration Administrator Tom Engels announced that HHS is initiating action to decertify Kentucky-based organ procurement organization Network for Hope during a press conference in Lexington, Kentucky.
According to HHS, multiple reviews identified persistent patient safety failures despite oversight and opportunities for corrective action. HHS stated that the organization's actions and inactions put patients at risk.
The AST will continue to monitor federal actions affecting the organ procurement and transplantation system and keep members informed of significant developments.
HRSA Update
AST Comments on Living Organ Donation Reimbursement Program
The AST submitted comments in response to the Health Resources and Services Administration's (HRSA) proposed “Modification of the Living Organ Donation Reimbursement Program Eligibility Guidelines in Response to the Honor Our Living Donors Act.”
The proposed changes would update eligibility guidelines for the Living Organ Donation Reimbursement Program to implement the Honor Our Living Donors (HOLD) Act. Through its comments, the AST provided the transplant community's perspective as HRSA considers changes to the program and continued its advocacy for policies that reduce financial barriers to living organ donation.
CMS Update
AST Leads Coalition Response on Medicaid Community Engagement Requirements
The AST led a coalition letter signed by 20 additional organizations in response to the Centers for Medicare & Medicaid Services' interim final rule establishing Medicaid community engagement requirements for certain individuals.
The letter urges CMS to exempt individuals awaiting or recovering from organ transplantation from these requirements, highlighting the unique medical circumstances facing transplant candidates and recipients and the importance of protecting access to Medicaid coverage during critical periods of care.
CMS Releases Proposed 2027 Medicare Physician Fee Schedule
CMS recently released the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule.
The Physician Fee Schedule determines Medicare payment policies and rates for services furnished by physicians and other health care professionals and can have important implications for the delivery and valuation of transplant care.
FAA Update
Drone Restrictions
The AST joined other organ donation and transplantation stakeholders in submitting comments to the Federal Aviation Administration (FAA) regarding its proposed rule, “Designation — Restrict the Operation of Unmanned Aircraft in Close Proximity to a Fixed Site Facility.”
The comments highlight considerations for the organ donation and transplantation community as the FAA develops policies governing unmanned aircraft operations near certain facilities. The AST continues to work with partners across the transplant community to ensure federal policies consider the unique needs of organ donation and transplantation.
Stay Engaged
Advocacy is strongest when it reflects the experiences and expertise of the transplant community. We appreciate the members who have already shared their feedback and ideas and encourage all AST members to continue the conversation.
Whether you have concerns about an emerging policy, an idea for an advocacy priority, or feedback on AST's current efforts, we want to hear from you.
The AST remains committed to representing the transplant community before Congress and federal agencies, championing policies that support patients and transplant professionals, and keeping members informed about the opportunities and challenges involved in achieving meaningful policy change.
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