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Change to Hospital-Based OPO Voting Privileges

Proposal Overview

Status: Review

Sponsoring Committee: Membership and Professional Standards

Strategic Goal 5: Promote the efficient management of the OPTN

Executive summary

There exist multiple types of OPOs: independent OPOs and hospital-based OPOs (HOPOs). Under the current OPTN Bylaws, only independent OPOs are permitted to vote in OPTN matters; HOPOs do not have any voting privileges in OPTN elections except as a part of their supporting hospital. Recognizing that some HOPOs serve multiple transplant hospital members within their DSA and their interests may not always align with the single hospital with which they are affiliated, this proposal would grant HOPOs a vote in OPTN regional and national matters if the HOPO is able to demonstrate functional separation between the OPO and transplant programs of the transplant hospital member.

Allowing HOPOs to have a separate vote would allow a DSA's organ procurement interests to be represented in OPTN voting matters and primarily supports the OPTN strategic goal of promoting efficiency in the management of the OPTN.

Read the proposal (PDF - 111 K; 8/2018)

Contact: Sally Aungier

Specific feedback

Does this proposal adequately describe the requirements for separation between the HOPO and transplant programs?


Please use this form to provide your feedback. Your comments relating to the proposal will be displayed in the comment section below (within 24 hours).

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IMPORTANT RULES ABOUT COMMENTING

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Anonymous | 8/9/2018

It is important that DSAs served by a HOPO have a voting voice in the OPTN governance process.  The seven HOPOs in the U.S. serve a wide variety of DSAs and in most cases multiple programs outside of their own hospital.  Representing the organ procurement voice is valued by the OPTN in the other 51 DSAs served by independent OPOs; it is appropriate the 7 HOPOs have the same opportunity.

Rene Romero | 8/20/2018

I believe HOPO's that can demonstrate clear structural and administrative independence from the associated Transplant Hospital that have been reviewed and approved by the MPSC should have a vote in OPTN governance. The requirements to define independence of a HOPO from a Transplant Hospital as outlined in the proposal are reasonable. I believe the voting privilege extension to HOPO's would come at a reasonable time as HOPO's will likely end up being responsible to more members in the transplant community as the functional significance of DSA's in general changes in the upcoming years. The proposal outlines that voting privileges can be surrendered voluntarily by reporting changes in HOPO structure to the MPSC. Grievances relating to any lack of independence between HOPO's and the affiliated Transplant Hospital relative to other Transplant Hospitals in a given DSA can be managed through existing MPSC channels.

Danielle Balbis | 8/21/2018

I appreciate the OPTN/UNOS' Membership and Professional Standards Committee's support of this proposal to allow voting privileges for hospital-based OPOs. The requirements outlined in the proposal for hospital-based OPOs to demonstrate separation with the transplant program where they are based are fair. I strongly support this proposal.

Region 4 | 8/31/2018

Region 4 Vote: 19 strongly support, 9 support, 2 abstentions/neutrals, 0 oppose, 0 strongly oppose

AOPO | 9/10/2018

The Association of Organ Procurement Organizations (AOPO) enthusiastically supports this proposal that will modify the OPTN bylaws regarding OPO membership in Appendix B, where hospital-based OPOs (HOPO) are denied independent voting rights. In light of the OPTN Final Rule (42 CFR, Part 121,3(iii)(2)), which requires admission of all OPOs as members of the OPTN: 'The OPTN shall admit and retain as members all organ procurement organizations,' and the fact that most hospital-based OPOs now serve more than one transplant hospital within their designated donor service area, it is essential that independent voting rights be afforded said organizations. It is important to note that HOPOs are not 'under the control' of the affiliated transplant hospital for actions taken for the purpose of donor evaluation, donor management, organ allocation and other functions provided in service to all transplant programs within the DSA. As it is for independent OPOs, HOPOs are neutral and incorporate recommendations from, and are accountable to, all transplant programs they serve in policy and protocol implementation, regardless of hospital affiliation. It is a fact that hospital-based OPOs operate in chains of accountability to hospital administration that are separate and distinct from transplant programs. The OPTN Bylaw Appendix B (limiting the voting rights of hospital-based OPOs) has been obsolete and should have been revised after publication of the OPTN Final Rule. Further, given the evolution of the structure and scope of operations of hospital-based OPOs, and the full construct of donation, transplantation and the broader community within which we all work and serve, the reasons for denying hospital-based OPOs voting rights are no longer relevant. There are 7 hospital-based OPOs in the U.S., and AOPO strongly supports this revision which will allow for a separate vote as hospital-based OPOs operate, conduct the business and the work of donation, and serve the community, just as any independent OPO.  Thank you for this opportunity to provide comment.

Region 3 | 9/11/2018

This proposal was a non-discussion agenda item. The Region 3 vote was as follows:

12 strongly support; 12 support; 8 abstentions/neutrals; 1 opposed; 0 strongly oppose

Region 8 | 9/12/2018

This proposal was a non-discussion agenda item. The Region 8 vote was as follows:

11 strongly support; 3 abstentions/neutrals; 0 opposed; 0 strongly oppose

Region 5 | 9/14/2018

The Region 5 vote was as follows:

11 strongly support; 18 support; 4 abstentions/neutrals; 0 opposed; 1 strongly oppose

Region 1 | 9/17/2018

Region 1 Vote: 4 strongly support, 8 support, 1 abstentions/neutrals, 0 oppose, 0 strongly oppose

Deanna Santana | 9/24/2018

I believe the HOPO and Tx center should be able to vote IF they serve Tx centers other than those at their own hospital.

Region 2 | 9/26/2018

Non-discussion agenda:
Region 2 Vote: 8 strongly support, 24 support, 2 abstentions/neutrals, 0 oppose, 0 strongly oppose

OPTN/UNOS Organ Procurement Organization Committee | 9/27/2018

The OPO Committee met by teleconference on 09/24/2018 to discuss the Change to Hospital-Based OPO Voting Privileges proposal. The Committee supported this proposal and provided no comments.

American Nephrology Nurses Association (ANNA) | 10/01/2018

ANNA supports.

American Society of Transplantation (AST) | 10/01/2018

The American Society of Transplantation supports this proposal if the OPO and the transplant program are functionally separate as described.

Region 9 | 10/01/2018

Region 9 vote:

8 strongly support, 10 support, 2 abstentions/neutrals, 1 oppose, 0 strongly oppose

Region 11 | 10/02/2018

Region 11 Vote: 8 strongly support, 14 support, 1 abstentions/neutrals, 0 oppose, 0 strongly oppose

American Society of Transplant Surgeons | 10/2/2018

The American Society of Transplant Surgeons (ASTS) supports this proposal to allow HOPOs the privilege to have an independent vote providing that they comply with regulations that establish a firewall between the transplant center and OPO leadership. If the HOPO is fully under the leadership and control of a transplant center, a second vote should not be permitted. ASTS recognizes that OPOs need to ensure adequate communication between OPOs and the OPTN on key issues. We recommend a policy that requires OPOs to provide documentation of an independent decision making process.

The American Society for Histocompatibility and Immunogenetics (ASHI) | 10/2/2018

The American Society for Histocompatibility and Immunogenetics (ASHI) strongly supports this proposal.  ASHI feels this proposal adequately describes the requirements for separation between the HOPO and transplant programs.

Elizabeth Rubinstein | 10/3/2018

I support the proposal and am in alignment with the statements as stated below in the proposal   MPSC committee discussion to safeguard the independent HOPO vote to provide fair and equitable representation.  1. The OPO administrative director* does not serve in a leadership role in the transplant hospital.  2. The OPO administrative director* does not report to leadership at the transplant hospital  *The administrative director refers to positions including but not limited to the Executive Director, Chief  Executive Officer or President of the OPO. The MPSC acknowledges that many OPO Medical Directors  appropriately serve in a leadership role in a transplant hospital. Full documentation and proof of influence separation should be requested to truly verify the above and should be considered as an addition to final policy implementation.

Region 7 | 10/3/2018

Region 7 Vote: 11 strongly support, 11 support, 5 abstentions/neutrals, 0 oppose, 0 strongly oppose

Region 6 | 10/3/2018

Region 6 Vote: 26 strongly support, 17 support, 1 abstentions/neutrals, 1 oppose, 0 strongly oppose

Region 10 | 10/3/2018

Region 10 Vote: 10 strongly support, 12 support, 2 abstentions/neutrals, 1 oppose, 2 strongly oppose