At a glance
The OPTN has bylaw requirements for transplant program key personnel training and experience as required by the OPTN Final Rule.
Changes have been made to sections of the training and experience bylaws, but a review of all bylaw requirements has not been done in over 10 years. As an initial phase, a review of the bylaws has been conducted to reveal inconsistencies between similar bylaws, outdated sections, and overly complex requirements.
Bylaw changes are being considered for the training and experience of key personnel bylaw sections. In a separate proposal, the Membership and Professional Standards Committee (MPSC) recommends changes to the membership and application bylaw sections. MPSC requests the following feedback from the community:
- Any unintended consequences for these proposed changes to primary surgeon and physician training and experience requirements:
- Consolidation of multiple pathways into one recent experience pathway
- Limiting procurement requirement for surgeons and observation requirements for physicians to surgeons or physicians that have not been a primary in last 10 years.
- Replace letters of reference and recommendation with online OPTN certification form
- Inclusion of conditional approval for both primary surgeons and physicians where there is an unanticipated vacancy
- Do you support the addition of an OPTN Orientation Curriculum for individuals who have not served as a primary surgeon or physician in the last 10 years? What should the curriculum cover?
- For individuals with foreign training or experience:
- How does one evaluate equivalent training to a board certified practitioner?
- Should an individual proposed as primary be required to have US transplant system experience? Can OPTN orientation curriculum replace experience?
- For future project evaluating alternatives to the current requirement that primary surgeons and physicians be “on site”:
- What responsibilities should the primary surgeon and physician have?
- What level of commitment should be demonstrated to fulfill the role of primary surgeon and physician?
- What it's expected to do
- Inform future bylaw proposals for revision of organ-specific primary surgeon and primary physician training and experience requirements
- What it won't do
- Will not change bylaws at this time
- Primary surgeon and primary physician training and experience
- Minimum requirements for transplant program leaders
Terms to know
- OPTN Final Rule: The Final Rule defines a standard framework for policies, requiring the OPTN to establish Policy Criteria, Policy Objectives and Performance Measures with procedures for continuous evaluation and reporting.
- Procurement: The surgical procedure of removing an organ from a donor. Also referred to as recovery.
- Transplant Program: The organ-specific facility within a transplant hospital.
- Transplant Physician (See Transplant Team): Doctors who manage the patient's medical care, tests, and medications. He or she does not perform surgery. The transplant physician works closely with the transplant coordinator to coordinate the patient's care until transplanted and provides follow-up care to the recipient.
- Transplant Surgeon (See Transplant Team): Doctors who perform the transplant surgery and may provide the follow-up care for the recipient. The transplant surgeon has special training to perform transplants.
- Click here to search the OPTN glossary
Kenneth Andreoni | 02/03/2021
I completely agree with the committee's goal of clarifying primary physician / surgeon requirements and for allowing prior primary physician / surgeon status to carry over into a new transplant hospital position. I would propose that 'logs' no longer be required once a physician / surgeon has been approved as a primary physician / surgeon. Some of us are still being asked to provide logs from fellowships completed 20 years ago and this should no longer be required. -Replace letters of reference and recommendation with online OPTN certification form - yes, and this should not be required after one has been approved as a primary physician / surgeon -addition of an OPTN Orientation Curriculum for individuals who have not served as a primary surgeon or physician in the last 10 years: this would be helpful and the MPSC and organ specific comm should create the content. For future project evaluating alternatives to the current requirement that primary surgeons and physicians be “on site" - I believe the intent of this concept has always been that a transplant physician / surgeon should be available in such as manner so that no organ offer / transplant is denied to a listed candidate. There also must be available expertise to care for transplanted patients post-transplant. I believe the primary physician / surgeon are responsible to work with the transplant administrator and ensure program compliance with all regulatory bodies, as well as ensure adequate medical / surgical care exists for transplant patients at that transplant hospital. The primary physician / surgeon should have a reasonable amount of direct patient care responsibilities (patient clinic and inpatient care for physicians, as well as operations for surgeons) at the transplant hospital on an ongoing basis.
Region 4 | 02/04/2021
During the meeting there were comments voiced during the discussion, submitted online and submitted as comments from the OPTN representatives. Overall, there was general agreement and support for this proposal. One attendee recommended that the committee address individuals who lead programs and then change centers, understanding that they are very experienced and not new to the role. Another attendee cautioned the committee about using performance standards, including volume requirements, adding that volume changes over time without changes in quality. There was concern from one attendee about the bias between having the same currency standards for high and low volume programs, adding that some small volume programs may be forced to close. One attendee suggested implementing a grandfather clause for foreseeable succession challenges. Finally, an attendee strongly supported decreasing the burden on transplant centers when making changes or submitting applications.
Region 3 | 02/18/2021
During the meeting there were comments voiced during the discussion, submitted online and submitted as comments from the OPTN representatives. There were several comments supporting the effort to make the process simpler. Two attendees commented that providing the required patient log can be challenging due to HIPPA regulations and suggested that these logs should be sent directly to UNOS. Another member suggested that patient logs might be pulled from NPI numbers that are entered into UNet. A follow up comment was made that this would not help with the compilation of logs for fellows because fellows are first assistants in the surgeries, and that data is not entered into UNet. Several comments were made about primary surgeon/physician approvals included that there should be more flexibility, incorporating minimum requirements to assess besides log numbers, and consideration for someone who has been primary at another transplant hospital.
Region 5 | 02/19/2021
During the meeting there were comments voiced during the discussion, submitted online and submitted as comments from the OPTN representatives. Overall, there was general agreement and support for this proposal. One member stated that Foreign Equivalency is an extremely difficult topic to approach. People struggle with it on the hospital level, the credentialing level, the state level and state licensing. This is their own opinion but a number of the American Society of Transplant Surgeons (ASTS) committee members struggle with this. There are quite well trained surgeons who come from various non-US countries who would be wonderful surgeons here but struggle with boarding and licensing issues. The member stated it is almost like you have to do it on a case-by-case basis. People’s training varies, and where, and what you did in your training. They did not know how to advise on this, but the foreign equivalence will be challenging. One member asked if UNOS has tried to put together a consortium of physicians from the American Society of Transplantation (AST) or ASTS to get on the same page with UNOS and CMS. They think we should get all the entities on the same page so we are not trying to reinvent the wheel. Another member asked if there is value in separating minimum standards versus some physicians who clearly exceed the experience standards required. The member stated that if you are making regulations to apply to everyone, it can be difficult to get a one size fits all. Whereas you can probably recognize a very experienced surgeon or physician that is able to fulfill all the requirements. These are two different things that you are aiming for. I am speaking as a foreign surgeon. For Foreign Equivalence, there is a concern about making requirements too broad. One of the concerns is that if they are not transparent to members, they would not find out until they have finished the application process that they are not considered qualified under the bylaws. There is tension between specificity and flexibility to not exclude qualified individuals. One member stated that one of the areas along with partnering with ASTS and AST, where they run into the biggest problem is not in the transplant community, it is the chairs who are not transplantors and the privileging credentialing folks who are not in the loop. They find themselves where commitments have been made outside of the transplanting community in those higher levels. Wherever the opportunities are to pull chairs, higher ups, and increase their awareness to what they need to think about in recruiting or the requirements would really save a lot of challenges in the space. One member commented that the ACS and ABS certification for international candidates has a conditional/alternative pathway that is a potentially powerful and standardized tool for our surgeons at least. Getting all these governing bodies on board so there is consistency. They agreed with getting other governing bodies onboard. They would recommend including the ACS and ABS as they have developed an international pathway to get foreign surgeons a ABS pathway through an alternative pathway.
ANNA | 02/25/2021
ANNA supports this proposal.