Families USA Submits Comments on the Increasing Organ Transplant Access Model

Too many people die waiting for kidney transplants while emerging clinical evidence demonstrates that organs previously deemed not fit for transplant could safely be used, therefore dramatically improving patients’ quality of life. To address this, CMS has introduced the Increasing Organ Transplant Access (IOTA) Model, on which Families USA has provided comments. This mandatory model is a promising step forward in advancing health equity and improving health outcomes for those with end stage renal disease (ESRD) and prioritizing the delivery of high-value health care.  

The model seeks to: 

• Address significant racial and socio-economic disparities with kidney transplant recipients. 

• Improve shared decision-making between providers and patients (i.e. giving patients enough information to participate in their transplant care).  

• Restructure payments to ensure that providers are focused on improving patient quality of life. 

• Increase the number of people who receive a kidney transplant, regardless of age, race, ethnicity, and socioeconomic status.  

Families USA strongly supports the work of CMMI to explore and implement promising new mandatory payment models for qualifying hospitals, and we applaud the design of the IOTA model as a mandatory model while also advising on areas of improvement to strengthen model design. Areas of improvement include the following:  

• Improve data collection and metrics on health equity, specifically social driver of health (SDOH) measures at both 365 days- and 3 year- post-transplant.  

• Improve health equity through increased performance-based payments that will direct a portion of the payments into a SDOH fund specifically for patients on a waitlist who may be experiencing financial barriers, such as those who may have difficulty affording post-operative care.  

• Improve shared decision making by requiring hospitals to facilitate conversations between kidney transplant candidates and qualified support personnel such as palliative care providers so that patients understand the unique tradeoffs of kidney transplantation. CMS should further provide participating hospitals with guidance on how to engage in these conversations.  

Models such as IOTA are setting the foundation for a shift toward meaningful, value-based care, all while addressing critical health inequities for patients with ESRD.