IOTA (Increasing Organ Transplant Access) Model

Background

On average, 13 Americans die each day while waiting for a life-saving kidney transplant. There are approximately 90,000 people on the kidney transplant waiting list, facing three to five years or longer for an offer. The IOTA Model builds on other federal initiatives dating back to 2018 to improve care for people with kidney disease, including the Burden Reduction Rule, the updated Organ Procurement Organization Conditions for Coverage, and the Kidney Care Choices (KCC) and ESRD Treatment Choices (ETC) models.

Goals

The model promotes the following goals:

• Maximize the use of deceased donor kidneys
• Improve quality of care before, during and after kidney transplantation
• Create greater access to kidney transplants by addressing barriers to care
• Identify more living donors and assist potential living donors through the donation process
• Improve care coordination and person-centeredness in the kidney transplant process

Innovation

The IOTA Model builds on previous efforts to improve the care continuum for people living with kidney disease, including ESRD.

The ETC Model, launched in 2021, focuses on improving quality of life with greater use of home dialysis and increased access to kidney transplantation. The KCC Model, launched in 2022, builds on the structure established by the Comprehensive ESRD Care (CEC) Model and aims to delay the need for dialysis for people with chronic kidney disease by improving the coordination and quality of care.

The IOTA Model is part of a wider effort by the Department of Health and Human Services’ Organ Transplant Affinity Group (OTAG), a collaboration of CMS and the Health Resources & Services Administration (HRSA), to increase access to organ transplants, improve accountability for the U.S. organ transplantation system, and increase the availability and use of donated organs.

Design

In performance year (PY) 1, participating kidney transplant hospitals only have the potential for a positive payment adjustment (upside risk); beginning in PY 2, they have the potential for either upside or downside risk. Based on their final performance score, participating kidney transplant hospitals will either:

• Receive upside risk payments from CMS or
• Fall in a neutral zone in which the kidney transplant hospital neither receives an upside risk payment nor owes a downside risk payment or
• Beginning in performance PY 2, owe downside risk payments to CMS.
   

The final performance score (100-point possible total) is calculated on a set of metrics in three domains:

• Achievement: based on the number of kidney transplants (60 points)
• Efficiency: based on the organ offer acceptance rate ratio (20 points)
• Quality: based on a post-transplant composite graft survival rate measure (20 points)

To determine participants, CMS selected half of the donation service areas (DSAs) and all eligible kidney transplant hospitals there, for a total of 103 kidney transplant hospitals, to participate in the mandatory model. The other half of kidney transplant hospitals serve as the comparison group for evaluation purposes. At the start of PY 2, July 1, 2026, the IOTA Model will have 95 eligible kidney transplant hospitals participating in the mandatory model. Eligible kidney transplant hospitals are non-pediatric kidney transplant hospitals with an active kidney transplant program that perform an annual average of 15 or more kidney transplants in each of the three baseline years before the start of the model on July 1, 2025. The model includes data-sharing requirements and incentives for participating kidney transplant hospitals to improve the patient experience and share information with attributed patients.

People seeking transplants receive a notice if their kidney transplant hospital is participating in the model. They retain their freedom of choice to seek care from any Medicare provider and are not limited to their attributed kidney transplant hospital.

Participant Resources

• IOTA Model Participant List (XLSX)
• Final Rule — Increasing Organ Transplant Access Model
• Notice of Proposed Rulemaking — Increasing Organ Transplant Access Model
• PY 2 Updates Final Rule (June 1, 2026)
• PY 2 Updates Notice of Proposed Rulemaking (December 11, 2026)

Events Archive

• IOTA Model Welcome Webinar (December 18, 2024): Slides (PDF)

• Fact Sheet (PDF)
• FAQs
• Participant Readiness Roadmap (PDF)
• Financial Fact Sheet (PDF)
• Achievement Domain Write-Up (PDF)
• PY 2 Updates — Quick Reference