ARTICLE
17 December 2024

CMS Finalizes Organ Transplant Access Model

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Manatt, Phelps & Phillips LLP

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On November 26, the Centers for Medicare & Medicaid Services (CMS) finalized its Increasing Organ Transplant Access (IOTA) Model, which aims to increase access to kidney transplants...
United States Food, Drugs, Healthcare, Life Sciences

On November 26, the Centers for Medicare & Medicaid Services (CMS) finalized its Increasing Organ Transplant Access (IOTA) Model, which aims to increase access to kidney transplants for patients living with end-stage renal disease (ESRD). The six-year model was initially set to launch on January 1, 2025, but has been delayed to July 1, 2025, to give participating hospitals and other stakeholders more time to prepare. The model builds on previous Center for Medicare and Medicaid Innovation models (i.e., the ESRD Treatment Choices and Kidney Care Choices models) to improve care for those with kidney disease and, in particular, seeks to:

  • Improve quality of care before, during, and after transplantation;
  • Maximize the use of deceased donor kidneys;
  • Identify more living donors and assist potential living donors through the donation process;
  • Create greater access to a kidney transplant by addressing social determinants of health and other barriers to care;
  • Improve care coordination and patient-centeredness in the kidney transplant process; and
  • Reduce Medicare expenditures.

CMS selected half of the donation service areas (DSAs) and all eligible kidney transplant hospitals in those areas—for a total of 103 hospitals—to participate in the mandatory model, with the other half of DSAs serving as the comparison group. Hospitals eligible for selection are non-pediatric transplant hospitals that perform an average of 11 or more kidney transplants per year in the three years leading up to the start of the model.

Participating hospitals are being provided with support to offer greater care coordination, improve quality of care, and address the health-related social needs (HRSN) of patients awaiting transplant. Additionally, hospitals are eligible to receive incentive payments based on their performance scores in three domains: achievement, efficiency, and quality. The model will use one-sided risk in performance year one and introduce two-sided risk beginning in performance year two.

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