CMS REQUIREMENTS
An Organ Procurement Organization’s (OPO’s) primary role is to ensure life-saving organs become available to critically ill patients who are on the transplant waiting list. There are many regulating bodies involved to ensure both the OPO and the Hospital follow national best practices to save as many lives as possible. Many of these regulations were first implemented in 1998 under the Conditions of Participation for Medicare Reimbursement (CMS).
The current CMS regulations for Hospitals are summarized below:
• Hospital must have a written contract with their federally designated OPO
○ Within that agreement, the responsibilities of both the OPO and the hospital must address donation
after circulatory death (DCD)
• Hospital must report, in a timely manner (within 60 min.), all deaths and imminent deaths (patients who are
identified as potential organ donors before death)
• OPO to determine medical suitability of potential donor
• Hospital must maintain potential organ donors while necessary testing and placement of potential donated organs,
tissues, and eyes take place
• Only trained requesters from the OPO are to have the donation conversation with families of potential donors
• Hospital and the OPO must collaborate in providing donation education to hospital Physicians and staff
AN INTRODUCATION TO FEDERAL REGULATIONS
The current CMS regulations for Hospitals are summarized below:
• Hospital must have a written contract with their federally designated OPO
○ Within that agreement, the responsibilities of both the OPO and the hospital must address donation
after circulatory death (DCD)
• Hospital must report, in a timely manner (within 60 min.), all deaths and imminent deaths (patients who are
identified as potential organ donors before death)
• OPO to determine medical suitability of potential donor
• Hospital must maintain potential organ donors while necessary testing and placement of potential donated organs,
tissues, and eyes take place
• Only trained requesters from the OPO are to have the donation conversation with families of potential donors
• Hospital and the OPO must collaborate in providing donation education to hospital Physicians and staff
AN INTRODUCATION TO FEDERAL REGULATIONS