Increasing Organ Transplant Access Performance Year 2 Model Update — Quick Reference

Current Policy:
Participants can submit voluntary health equity plans.

New Policy:
Removes voluntary health equity component.

Current Policy:
Model participation is mandatory for all eligible kidney transplant hospitals selected for participation, which include:  

Hospitals that performed at least 11 kidney transplants for patients 18 years of age or older annually regardless of payer type during the three-year period ending 12 months before the model’s start date.

Hospitals that are non-pediatric transplant facilities that furnished more than 50% of the hospital’s annual kidney transplants to patients 18or older during that same period.

New Policy:
Increases the low-volume threshold from a minimum of 11 kidney transplants performed during each of the baseline years to 15 and modifies the eligible kidney transplant hospitals criteria to exclude military medical treatment facilities and VA medical facilities as defined at § 512.402. 

Current Policy:
Upside risk payments and downside risk payments are only based on kidney transplants for beneficiaries with Medicare Fee-For-Service (FFS) as a primary or secondary payer multiplied by a multiplier of $15,000 for a maximum upside payment and $2,000 for a maximum downside payment, scaled by each IOTA participant’s score out of 100.

New Policy:
Allows for the inclusion of Medicare Advantage (MA) patients in the definition of Medicare kidney transplants so that upside risk payments and downside risk payments are only based on kidney transplants for beneficiaries with Medicare FFS or MA as a primary or secondary payer while maintaining maximum upside risk payment at $15,000. 

Current Policy:
The composite graft survival rate does not include a risk adjustment methodology and does not exclude dual organ transplants.

New Policy:

• Updated risk-adjustment methodology for the composite graft survival rate that is based on an adapted Scientific Registry of Transplant Recipients framework and tailored to align with the composite structure of the metric.
• Exclusion of transplants (except for kidney/pancreas) to the composite graft survival rate exclusion and inclusion criteria
• Updated point allocation:
  • IOTA participants in the 87.5th percentile of performers and above, 20 points.
  • IOTA participants in the 75th to below 87.5th percentile of performers, 18 points.
  • IOTA participants in the 62.5th to below 75th percentile of performers, 15 points.
  • IOTA participants in the 50th to below 62.5th percentile of performers, 13 points.
  • IOTA participants in the 37.5th to below 50th percentile of performers, 10 points. IOTA participants in the 25th to below 37.5th percentile of performers, 8 points.
  • IOTA participants in the 12.5th to below 25th percentile of performers, 5 points.
  • IOTA participants who are below the 12.5th percentile of performers, zero points. 

Current Policy:
Participants are not required to notify eligible Medicare beneficiaries when an organ is declined on their behalf and are not required to notify Medicare beneficiaries when their waitlist status changes.

New Policy:
Beginning in PY 3, participants must provide semi-annual notifications to Medicare beneficiaries who are active and have been on their waitlist for at least three years, detailing the number and reasons for organ declinations made on their behalf, with patients retaining the right to opt out of receiving these communications.  

Additionally, participants must notify Medicare beneficiary waitlist patients of status changes within 10 days when they become ineligible for organ offers (if not redundant with existing HHS guidance), providing the reason, reactivation information, and notifying the patient's dialysis facility and nephrologist/managing clinician when applicable.