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The CMS Mitigating Factors Process for Solid Organ Transplant Programs – Notice of Proposed Rule-Making (NPRM) - Informational Only
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Publication of NPRM: CMS-1607-P was published on May 15, 2014. The proposed rule updates the Inpatient Prospective Payment System (IPPS) for hospitals. The NPRM also includes program updates for certain other acute care providers. This S&C memorandum summarizes only the proposals related to solid organ transplant programs. Transplant Mitigating Factors Process: Current regulations permit a transplant program to apply for consideration of mitigating factors that, if approved, would permit the program to continue to participate in Medicare despite not fully meeting CMS requirements for patient or graft survival. This proposed rule would clarify the mitigating factors process, increase transparency, and explicitly recognize CMS willingness to consider program improvements and the use of innovative practices as part of the mitigating factors process.