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​​Clarify Requirements for Pronouncement of Death​

eye iconAt a glance

Current policy

OPTN Policies 2.15.G: Pronouncement of Death and 2.14.A: Conflicts of Interest need to be updated so that there is clarity and consistency between the two policies. These policies speak to which healthcare professionals should pronounce death for a potential donor. However, they do not coincide with current Organ Procurement Organization (OPO) practice to employ or contract with multiple physicians who are hospital intensivists to provide on-call medical director services. When not on call for the OPO, the contracted physicians may need to participate in the pronouncement of death as part of the donor hospital healthcare team. Currently the policies are too broad to monitor and do not give enough clarity for OPOs and the Member and Professional Standards Committee (MPSC) to determine if there is a potential policy violation.

Supporting media

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Proposed changes

  • Updates policies to ensure consistency between donation after circulatory death (DCD) and donation after brain death (DBD) policies about pronouncing death
  • Revises policy language for consistent terminology
  • Explicitly states that the healthcare professional who declares death cannot be involved in any aspect of the organ recovery procedure or transplantation of that donor’s organs

Anticipated impact

  • What it's expected to do
    • Updates policy language for both applicable sections of OPTN Policy (14.A Conflicts of Interest and 2.15.G Pronouncement of Death), so that both sections are consistent with each other
    • Modifies language to be donor-specific
    • Updates language that references who can declare death
  • What it won't do
    • Does not change state/local statutes or regulations
    • Does not change that death is declared in accordance with hospital policy and applicable state and local statutes or regulations
    • Does not prevent OPOs and donor hospitals from the ability to develop their own institutional policies to ensure protection from conflicts of interest
    • Does not change OPTN position on DCD

Terms to know

  • Organ Procurement Organization (OPO): An organization authorized by the Centers for Medicare and Medicaid Services, under Section 1138(b) of the Social Security Act, to procure organs for transplantation.
  • Donation after Circulatory Death (DCD): describes the organ recovery process that may occur following death by irreversible cessation of circulatory and respiratory functions. A DCD donor may also be called a non-heart beating, asystolic, or donation after cardiac death donor.
  • Donation after Brain Death (DBD): describes the organ recovery process that may occur following death by irreversible cessation of cerebral and brain stem function; characterized by absence of electrical activity in the brain, blood flow to the brain, and brain function as determined by clinical assessment of responses. A brain dead person is dead, although his or her cardiopulmonary function may be artificially maintained for some time.
  • Membership and Professional Standards Committee (MPSC): OPTN Committee that is charged with monitoring compliance with OPTN obligations, including addressing risks to patient safety, public health, and OPTN integrity.

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Read the full proposal (PDF)

Provide feedback

eye iconComments

Anonymous | 02/22/2024

I believe there should be a standard set of practices for pronouncement of death that does not vary between centers based on an ethical assessment of the options available for defining death.

Anonymous | 02/21/2024

This is a good update to clarify the two policies. Having consistent language between policies, especially when referencing pronouncement of death, is very important. It is also crucial to be able to determine if a violation occurred, and have straightforward and clear guidelines to follow.

Anonymous | 01/30/2024

With transplant stigmas being that the doctors will not save you if you are an organ donor it may be a good foundation to have cut and dry requirements to check off.