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An important message from the OPTN Board President on the implementation of waiting time adjustments for kidney transplant candidates affected by the use of eGFR race-based calculations

Published on: Monday, December 4, 2023

OPTN Board President, Dianne LaPointe Rudow, ANP-BC, DNP, FAAN, recently sent a communication to all kidney programs with outstanding requirements for OPTN Policy 3.7 D. This important initiative corrects waiting time for kidney candidates who may have been negatively affected by previous race-inclusive eGFR calculations. The communication highlighted the requirements of the policy which are required to be completed by Jan. 3, 2024. Those requirements are outlined as follows:

By Jan. 3, 2024, the policy requires all adult and pediatric kidney programs to:

  • Notify all kidney candidates on their waiting list of the requirements of the transplant program according to the policy (initial notification)
  • Assess their respective kidney waiting lists to identify all affected Black kidney candidates and determine whether a race-neutral eGFR calculation shows candidates should have qualified sooner to start accruing waiting time for a transplant
  • Submit completed waiting time modification requests to the OPTN for every candidate who should have qualified to accrue waiting time sooner
  • Send a second notification to inform each kidney candidate of their eligibility status
  • Provide an attestation to the OPTN that the above requirements have been met

Programs can submit attestation documentation prior to Jan. 3, 2024

Attestations can be submitted prior to Jan. 3, 2024, and a number of kidney programs have already done so. The OPTN encourages programs to submit attestation documentation as soon as possible.  If you have completed the review of your waiting list, you may submit your attestation now.

The OPTN realizes that waiting list size and composition differ by each program. It may be that some programs with few potentially affected candidates wish to wait until closer to the January deadline. Please note that many observers inside and outside the transplant community, including the American Society of Nephrology, National Kidney Foundation, and Health Resources and Services Administration, are closely monitoring progress on this initiative and are maintaining a collective commitment to this vital initiative. The OPTN strongly encourages you to accelerate your review, modification, and attestation processes.

Regardless of when the attestation documentation is submitted, you must continue to fulfill all policy requirements, including notifications, for any patients added to the waiting list until Jan. 3, 2024. However, you will not be required to re-attest.

After Jan. 3, 2024, all kidney transplant programs will be required to:

  • Continue to notify all newly registered kidney candidates of the requirements of the transplant program according to the policy (initial notification)
  • Assess newly registered kidney candidates to determine eligibility
  • Submit completed waiting time modification requests to the OPTN for every candidate who should have qualified to accrue waiting time sooner

Kidney programs who do not submit attestation documentation by Jan. 3, 2024
 
When the OPTN becomes aware of a member’s potential noncompliance with OPTN obligations, the OPTN will gather information about the incident for OPTN Membership and Professional Standards Committee’s (MPSC) review. The MPSC reviews the information to determine the appropriate action based on the case type and member response. Programs that have not met the requirements by Jan. 3, 2024, may be identified as out of compliance. Immediately after the deadline, the OPTN will request information about a program’s progress and an explanation of the failure to comply. Members will have one week to respond, and the MPSC will review the responses and take appropriate action.
 
Resources on OPTN website

If you need additional information to complete the policy requirements, there are a number of resources to help you as follows: