New CMS Living Donor Regs??

We have recently become aware of pending CMS regulations regarding relationships between centers where living donor organs are recovered and centers where the organs are transplanted. This was the subject of a conference call on October 28 that was widely attended. The essence of the new regs is that the transplanting center holds at least partial responsibility for standards at the recovery center. You can access the proposal here. AST is in the process of preparing a formal response; what should that response include?


 

Comments

These regulations are well beyond what is written in the CoPs. These proposed regulations would put transplant centers in the situation of monitoring each others' performance and QAPI programs which is the responsibility of CMS and UNOS. What needs to be the focus is that in episodic swaps (and this needs to be defined), the responsibility of the recipient center does not extend past ensuring that the center is CMS certified....The concept that the tx center be required to review the donor chart for evidence that the COPs were met is not appropriate - that standard does not exist for deceased donors. Transplant centers are not responsible for monitoring that OPOs adhere to the CoPs for which they are responsible. To require us to monitor other centers that recover living donors is inappropriate.

This article is fundamentally flawed in accuracy and its recent publication severely discredits the criteria for brain death, or death by neurological criteria. These proposed regulations would put transplant centers in the situation of monitoring each others' performance. windows 8 transformation pack for xp

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