Coalition Submits Recommendations to HHS

Coalition responds to call for comments from HHS on future rulemaking aimed at improving organ donation and transplantation

The Coalition had the opportunity to kick-off 2022 with a meaningful impact by submitting comments to the U.S. Department of Health and Human Services, through the Centers for Medicare and Medicaid Services on ways that the government can improve both the organ transplantation system and dialysis care. 

Read the full letter here.

Synopsis of key recommendations:

Conduct Dialysis & OPO Systems Reviews

To level set and understand the state of the ecosystem it is imperative to begin with a review of the current systems in place. We recommended the study include the participation of practitioners, patient advocacy groups, federal regulators, and legislators to ensure that key stakeholders had a voice in the process.

Elevate Advocacy Organization Programming
Transplant advocacy organizations are intimately familiar with the needs of the community they serve and have developed effective programming to help improve education, access, and equity. To aid these processes already in place, we recommended instituting federal and state funding to these organizations to bolster essential programs and reach the communities in most need.

Expand Education
In addition to the financial support of educational programs already instituted by advocacy organizations, we recommended the development of a formal education program that will nationalize successful programs to promote and highlight organ, eye, and tissue donation as well as “transplant related” modules for medical schools and nursing programs.

Improve Equity
Working to establish a more equitable transplant ecosystem should be a top priority of CMS. We recommended federal funding to support additional transplant programs for hospitals in areas that treat and care for people of color. We also recommended investment in the Community Relations Departments of OPO’s to build trust and organ donation awareness in historically underserved populations and communities.

Increase Access
Access and equity are deeply intertwined. There can be no equity without fair access. While there are many areas of access to tackle, we specifically highlighted access to affordable housing and coverage of expenses during patient evaluation, pre-processing and post-proccessing. We also recommended life-long access to affordable anti-rejection medicine and care.

The Importance of Living Donation
Finally, we stressed the importance of living donation and the need for funding to drive educational programming through advocacy organizations focused on living donation.

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Finding the Perfect Match