Comments

OPTN Ad Hoc International Relations Committee | 03/20/2024

The OPTN Ad Hoc International Relations Committee (AHIRC) thanks the Executive Committee for the opportunity to provide feedback on their proposal, OPTN Strategic Plan 2024-2027. The committee needed clarification about whether continuous distribution (CD) projects are within the scope of the proposed strategic plan and strongly encouraged the Executive Committee to consider CD.

A member complimented the proposed strategic plan's simplicity, explaining that it seems concrete, specific, and narrow in scope. Members also agreed with the metrics. Other members recommended frequent assessments and monitoring updates to assess the goals.

UC San Diego Health Center for Transplantation | 03/20/2024

UCSD Center for Transplantation (CASD) appreciates the effort the Executive Committee put forth in drafting the proposed 2024-2027 OPTN Strategic Plan as well as the opportunity to comment. While CASD supports the overarching concepts encompassed we are concerned about the lack of explicit focus on the components of the vision and detail in the goals. Additionally, the plan as drafted, poses risk and consequence of current goal related committee projects being deprioritized and overlooks many of the critically important areas of current focus such as equity, safety, living donation, the ability to incorporate new data elements (ex. NRP) for collection, study and potentially further systemic improvement.

Calvin Henry | 03/19/2024

I agree that the 3 goals listed are appropriate but am surprised that the Executive Committee/Board of Directors doesn’t believe that equity in access to transplant should be a goal when major inequities continue within the OPTN which disadvantage certain candidates and also engender mistrust with the population. This is a glaring miss, in my opinion. I notice that other governmental health agencies (e.g., CMS) continue to focus on equity progress which is a foundational pillar of the executive branch of the current administration.

I also don’t find any metrics within this proposal. Metrics should be clear and measurable. For instance, if the OPTN wants to increase the number of transplants by 20% - that would be a metric. If I say the OPTN wants to increase the number of transplants - that is not a metric. How many trainings should transplant professionals receive vs patients? How will the OPTN measure success? If at the end of term, the OPTN increases transplants by 1% is that success? Throughout this proposal, I cannot find any metrics, measurements, or landmarks although I read that there should be 19. Without those, it is not possible to determine success at term’s end or determine if the plan is on track midway through the term or if course corrections are needed. When a strategic plan generates more questions than a vision and clear plan, I think further conversations should occur.

It’s promising to perhaps see what appears to be the thought of the OPTN perhaps in the fledgling stages of adopting an Agile methodology but, within Agile systems, the teams still need the vision and clear goals/metrics against those goals before they can organize and begin work.

Without any measurables or markers to measure progress as well missing a major opportunity with equity for transplant candidates, I believe this proposal could use additional work and, as such, I do not support it as currently written.

Infinite Legacy | 03/19/2024

Infinite Legacy supports the Strategic Plan’s goals and timelines; however, we suggest implementing specific metrics that include defining and monitoring of late turn downs, logistical challenges, and capacity of transplant centers. Consolidation of OPOs and OPTN contract bidding and implementation may lead to re-prioritization and establishment of specific goals related to this. Utilization of organs is a complex process, and continued attention to identifying areas of growth in transplants, specifically with the use of offer filters and the Matching system, should be included in the Strategic Plan. Increased specificity to ensure concrete metrics and timelines would be helpful to all parties involved. Additionally, the stance of CMS and other entities is such an integral part of what will unfold; this should be addressed.

International Society for Heart and Lung Transplantation | 03/19/2024

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OPTN Transplant Administrators Committee | 03/19/2024

The OPTN Transplant Administrators Committee appreciates the opportunity to comment on the OPTN Executive Committee’s proposal 2024-2027 Strategic Plan. The Committee offers the following feedback for consideration:

•There is some concern that the pillars of the strategic plan did not explicitly mention metrics around safe and effective patient care outcomes which are integral to the work of the OPTN. 

•The Committee suggests incorporating metrics related to system costs, such as OPO costs, decline rates, and transportation modes, when considering policies.

•It was suggested that a 6-month cadence would be appropriate for the frequency of reporting metrics to the Board of Directors, although real-time reporting would also be an optimal scenario.

•Members expressed the importance of not losing sight by promoting community buy-in by overly focusing on metrics like time to develop complex policies.

Overall, the Committee supports this proposal and advises the Executive Committee to take the above considerations into account.

Region 10 | 03/19/2024

3 strongly support, 16 support, 2 neutral/abstain, 0 oppose, 0 strongly oppose

Members of the region are supportive of the Strategic Plan. One attendee noted that with the OPTN Modernization Initiative it would be helpful to have insight from HRSA as to the future of the Strategic Plan and if changes will occur as part of the Modernization Initiative. Another attendee would like to see initiatives added to the Strategic Plan around living donation given the living donation numbers have stayed relatively the same while deceased donation continues to increase each year. Another attendee noted that efforts to improve organ non-use should primarily be focused on kidney allocation and distribution. The non-renal organs are improving with practice change and improved technology. The kidney need is the most substantial and optimizing kidney utilization should be a primary focus of OPTN efforts. Lastly, and attendee suggested focusing on the non-transplant parts of making the nation's transplant system work, such as support for transplant professionals, transplant hospitals, etc. Increasing the number of transplants is more than just can we have more organs recovered and distributed with equity to more programs/patients.

American Nephrology Nurses Association | 03/19/2024

Requested feedback:

•Do you agree with the Board’s proposed areas of strategic focus for the 2024-2027 plan? Yes. ANNA agrees.

•Is a goal or objective missing from this plan that should be considered a strategic priority? ANNA recommends adding Living Donor Transplantation as a focused goal. We feel this will enhance the other proposed goals.

•Are there goals or objectives that should not be included in this plan? N/A If so, should they be maintained in the OPTN’s future operations or discontinued altogether? N/A

•Are the stated performance metrics sufficient, measurable, and specific? Are metrics missing from this plan that are needed to provide a holistic view of progress on strategic priorities? ANNA believes more specific details need to be added about performance metrics in order to effectively achieve the proposed goals.

•What organs are at the greatest risk of non-use? N/A

American Society of Nephrology | 03/19/2024

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Region 9 | 03/19/2024

1 strongly support, 8 support, 1 neutral/abstain, 0 oppose, 0 strongly oppose

Overall, the region supports the proposal. A member commented that it would be nice if the OPTN Learning Management System was easier to access for patients, like if offerings were available without having to log in to something. The member added that it would also be helpful to understand the number of non-used organs offered to adults versus pediatric patients. An attendee suggested including a specific percentage decrease for the metric on organ non-use. A member commented that OPOs really need to consider whether an organ should be recovered with the intention to transplant. Another attendee said that the OPTN should help OPOs determine whether an organ should be recovered, and that artificial intelligence should be able to give an estimated organ utilization percentage. The attendee added that the RUM report is a good guideline, but it needs to be more robust.

OPTN Kidney Transplantation Committee | 03/19/2024

The OPTN Kidney Transplantation Committee thanks the Executive Committee for their work on this proposal and the opportunity to provide comment. Members noted that the OPTN organ-specific committees have been working towards developing, proposing, and implementing Continuous Distribution, and that this work is not well reflected in the proposed strategic plan. Members added that the initial strategic goal of Continuous Distribution was to increase equity in access to transplant, and that efficiency is only one goal in the greater Continuous Distribution framework.

Members also emphasized the importance of defining “successful transplant,” noting that this definition varies greatly by patient and program.

The Committee expressed concern that the proposed strategic plan does not place high enough priority on equity. Members noted that the proposed strategic plan presents a sense that equity has been fully realized, when in reality, there are still patient populations that lack equitable access, particularly among rural patients and non-English speaking patients. Members added that there are still equity gains to be achieved, and that equity should remain a high priority for the OPTN.

The Committee emphasized the importance of ensuring the patient community and general public understand the changes occurring within the transplant system, particularly regarding increased patient-centered focus.

OPTN Organ Procurement Organization Committee | 03/19/2024

The OPTN Organ Procurement Organization (OPO) Committee thanks the OPTN Executive Committee for their efforts on the OPTN Strategic Plan 2024 – 2027 proposal.

In discussing which organs are at the greatest risk of non-use, the Committee noted that there could likely be a comprehensive list of characteristics that could be used to identify organs, however, that must be data-driven. Committee members also indicated that organ quality is a major factor in describing organs that are at the greatest risk for non-use, and logistics and timing are also important considerations. While the Committee appreciates the focus on improving the efficiency of the system, there are concerns surrounding current and future projects that may improve the overall system but may not be addressed by the goals outlined in the plan.

OPTN Membership & Professional Standards Committee | 03/19/2024

The Membership and Professional Standards Committee (MPSC) appreciates the work done by the Executive Committee to develop this proposal and the opportunity to provide feedback. A member voiced support for the strategic plan but noted the variability among transplant centers across the OPTN and considered that a nationwide approach may not be the best method for developing metrics. Another member recommended including efficiency in donor process and considering how efficiency could be incorporated in continuous distribution beyond distance. A member recommended modifying the practice of measuring the non-use rate metric by donor service area (DSA) since DSA’s are a geographic distinction reflective of OPOs and OPOs are not the ones that use organs.

Anonymous | 03/19/2024

We recognize the critical role The Organ Procurement and Transplantation Network (OPTN) plays in the coordination and facilitation of organ donation and transplantation across the United States. As we look towards the years 2024-2027, we believe it is imperative for OPTN to adapt to the evolving landscape of healthcare, technology, and societal needs. Here are some key recommendations for OPTN's strategic plan during this period.

1. Enhance Communication and Education:

• Educate OPO’s and healthcare professionals about emerging concepts such as donor care facilities and dedicated perfusion facilities and promote a liaison between these independent organizations.

• Utilize diverse channels such as social media, webinars, and community events to disseminate accurate information about organ donation, transplantation processes, and OPTN's role.

• Invest in educational resources to ensure healthcare professionals are well-informed about the latest practices, guidelines, and advancements in transplantation. This is critical in an era of technological advancement in both organ perfusion and preservation. Educational programs should focus on practices from centers in North America that have the highest rates of acceptance and best risk adjusted outcomes

2. Embrace Technological Innovation:

• Leverage technologies that have been demonstrated to maximize organ acceptance rates. In an article published in 2023 from Peel and colleagues in the Annals of Surgery, a retrospective cohort analysis showed that both perfusion availability and use were associated with significantly increased rates of transplantation in lungs. Ex vivo lung perfusion was also associated with more donation after circulatory death and extended-criteria donor transplantation.

• Leverage emergent organ preservation technologies which have shown safe extended preservation times beyond what is defined in OPTN guidance documents. With new data being oublished and presented after well designed studies, amended policies, procedures and guidelines should be created and shared in order to improve organ placement efficiency.

• Leverage advancements in technology such as artificial intelligence, data analytics, and telemedicine to streamline organ allocation processes, enhance patient matching, and improve post-transplant care.

• Invest in digital platforms to facilitate communication and data sharing among transplant centers, organ procurement organizations (OPOs), and other stakeholders, ensuring timely and accurate information exchange.

• Explore opportunities for virtual organ assessments and donor evaluations to expand the donor pool and reduce geographic barriers to transplantation.

3. Strengthen Collaboration and Coordination:

• Foster closer collaboration among transplant centers, OPOs, regulatory agencies, and patient advocacy groups to optimize organ procurement, allocation, and transplantation processes.

• Standardize training for third party procurement organizations, including the development of guidelines for standardized organ assessment metrics.

• Enhance coordination with international transplant organizations to promote best practices, harmonize standards, and facilitate cross-border organ sharing where appropriate.

4. Prioritize Research and Quality Improvement:

• Promote data-driven quality improvement efforts by encouraging transplant centers and OPOs to participate in benchmarking activities, outcomes reporting, and collaborative learning networks.

5. Redefine policy development processes:

• Removal of disincentives that punish the aggressive use of marginal organs such as reimbursement benchmarked by transplant outcomes.

• Fund procurement in scenarios that may not always yield an organ for transplant.

We believe these recommendations will help OPTN position itself to meet the evolving needs of the transplant community, promote equity and access, drive innovation, and ultimately improve outcomes for transplant patients across the nation.

OPTN Minority Affairs Committee | 03/19/2024

The OPTN Minority Affairs Committee (MAC) appreciates the opportunity to comment on the Executive Committee's proposal, Strategic Plan 2024-2027. While the MAC generally agrees with decreasing non-use of organs and increasing efficiency in the transplant community, members have concerns that the proposed strategic plan does not explicitly include an objective that calls for equity gains. A member shared concern that while an increase in efficiency with placing organs may increase transplantation for larger centers, smaller centers may be left with less organs and therefore become geographically disadvantaged. One member referenced an objective in the goal of "Improve Offer Acceptance Rate" that discussed promotion of education programs for patients and suggested that indigenous populations would benefit from such education. The MAC expressed that the proposed goals may widen the current equity gap that impacts the most disenfranchised individuals with organ failure. The MAC recommends the transplant community be aware of these potential unintended consequence and asks the Executive Committee to monitor for any decrease in current equity gains.

Region 6 | 03/19/2024

1 strongly support, 7 support, 4 neutral/abstain, 1 oppose, 0 strongly oppose

Several attendees commented that the goals are too narrow and do not incorporate enough of the necessary work of the OPTN. They added that while some universal goals can be part of the organization's vision and not listed as strategic goals, some need to be explicit. There was also concern from several commenters that equity is not included in the plan, especially for vulnerable populations such as children. There was also concern that living donation was not included and the plan provides minimal opportunity for Living Donor Committee project prioritization. One attendee recommended that the committee consider a plan for the potential mass decertification of OPOs.  

NATCO | 03/18/2024

NATCO appreciates the diligent work by the OPTN in putting forth the strategic plan for the 2024-2027 period. The proposed goals to enhance organ acceptance, optimize organ use, and improve OPTN efficiency can positively impact the process by increasing the number of successful transplants. Our membership is in agreement with the proposed goals with the following comments for your consideration:
Goal 1: The proposal for monitoring the time from organ offer to acceptance and the rate of acceptance is realistic. The proposed metrics should be tools for quality improvement and should not evolve into disciplinary measures.
Goal 2: Developing a plan to identify opportunities and barriers to organ utilization by collaborating with all stakeholders is integral to the success of this goal. Open-offer organs should be excluded or calculated separately from standard organ transplant outcomes. Continuous transparency in allocation process promotes trust. Alignment between HRSA, CMS and transplant centers is paramount as it pertains to data collection point requirements to promote an effective and time efficient process.
Goal 3: We agree with the establishment of a timeline for policy development that aligns with the strategic plan, as well as a data optimization algorithm.
Additionally, identifying means to incentivize living donation, protect the rights of living donors, optimize and expand paired donation should be an immediate priority.

OPTN Policy Oversight Committee | 03/18/2024

The Policy Oversight Committee appreciates the opportunity to comment on the Executive Committee’s 2024-2027 OPTN Strategic Plan proposal. Members commented that the proposed strategic plan and its goals are too narrow in scope, appear to be tactical in nature, and may be overlooking other important areas such as equity, safety, living donation, long-term outcomes, and ongoing critical projects like continuous distribution and multi-organ transplant. The Committee feels this plan is an abrupt shift in OPTN focus and does not build on past strategic plan gains, nor does it incorporate context of ongoing projects. The Committee suggests broadening the strategic goals to explicitly include living donation, equity, safety, and ability to incorporate new data elements (ex. NRP). In response to the Executive Committee’s question “What organs are at the greatest risk of non-use?” members commented this question should be answered with available data vs. community input. Members expressed concern for the metrics outlined in the plan causing unintended consequences to other areas important to the community not outlined in the proposed goals. Members commented that the added transparency for patients is a welcome addition to the strategic plan, however there is concern for patient safety and equity not being explicit within the plan’s goals.

Members expressed concern that potentially deprioritizing current projects may lead to disengagement from the community and committee volunteers. Long-term, ongoing projects such as continuous distribution have been a significant investment of community time and effort. Deprioritizing this work may give the impression that it is no longer important. With this in mind, the POC supports maintaining the strategic policy priorities in progress to allow these projects to continue to completion. The POC requests clarity on the Executive Committee’s vision for current committee projects and strategic policy priorities.

Members expressed concern regarding the future role of the POC in the proposed strategic plan and potential changes to the policy prioritization process. The POC requests clarity from the Executive Committee on how projects that are not clearly aligned with strategic plan goals should be evaluated, prioritized, and resourced. POC members encourage a stronger partnership between the POC, Executive Committee, and Board of Directors in evaluating committee work, prioritizing, and resourcing.

OPTN Data Advisory Committee | 03/18/2024

The OPTN Data Advisory Committee (Committee) thanks the OPTN Executive Committee for presenting the Strategic Plan 2024 – 2027 proposal during the Committee’s March 11, 2024 meeting, especially the discussion of enhancing OPTN data collection. The Committee highlighted their rapid response to HRSA’s request for assistance identifying potential pre-waitlist data collection as the type of enhancement the OPTN should be working towards. Collection of information about the broader population of patients, such as those in the referral and transplant program evaluation and selection stages, should substantially improve the OPTN’s policy development and evaluation efforts and better serve those in need. It was also stated that the Committee would be very supportive of identifying an improved process for adding, modifying, and removing OPTN data that relies less on the involvement and approval of the U.S. Office of Management and Budget to make changes. It was suggested that a tiered hierarchy including a fast-track process for reviewing, approving, and implementing data changes should be considered. The Committee welcomes the opportunity to play a primary role assisting the OPTN Board to frame the objective “Enhance OPTN Data Collection” under the proposed goal of enhancing OPTN efficiency.

OPTN Lung Transplantation Committee | 03/18/2024

The Lung Transplantation Committee appreciates the opportunity to provide feedback on the proposed OPTN Strategic Plan for 2024-2027. Some members are concerned that the proposed plan does not consider the challenges and needs of the lung transplant community. Non-use rates for lung are relatively low compared to other organs, however, low utilization rates for lung represent an area for improvement. Members identified the misalignment of incentives between donor hospitals and OPTN members during allocation and recovery as a barrier to achieving the proposed goals. The availability of donor data is critical to decision-making for lung offer acceptance, and ultimately, the ability to manage donor lungs until recovery. The Committee encourages the development of a relationship between the OPTN and Centers for Medicare and Medicaid Services (CMS) to begin addressing these issues.

Though the Committee understands that lung-specific projects may still be proposed, members expressed concerns that they might not be approved due to misalignment with strategic plan goals. Members discussed that better stratification on the waitlist and evaluation of post-transplant outcomes are highly desired. One member shared anecdotal concerns that some lung transplant surgeons may feel pressured to accept high risk organs to meet the proposed metrics. The member explained that this disadvantages smaller programs and candidates in rural areas as they do not have the resources to manage high risk lungs in a way that promotes positive post-transplant outcomes.

OPTN Ethics Committee | 03/18/2024

The OPTN Ethics Committee thanks the OPTN Executive Committee for the presentation and for the opportunity to provide feedback on the proposed strategic plan.

The Committee thanks the Executive Committee for including equity in the plan’s foundation, however, notes concern that they are not mentioned specifically in the goals, objectives, or metrics. Without being included specifically, the Committee is concerned that important equity concerns will be left out of OPTN work, possibly undermining past gains in this area. The Committee views including equity in the goal as a utility consideration: the OPTN will be its best representative to the transplant community, maintaining the trust of the community, if it is seen as doing its due diligence in featuring all aspects of principles which guide procurement, distribution, and allocation of organ transplantation, including and especially the principle of equity. We fear that if equity is not mentioned specifically in the strategic plan, it will become increasingly under emphasized over time. While the Committee understands the framing chosen to “maintain equity” instead of “improve equity,” noting some pressing issues in the system that may require solutions less focused on improving equity, members urge the Executive Committee to consider public trust, transparency, and the importance of not only maintaining, but striving to improve equity in all aspects of the OPTN.

The Committee also notes that it may be helpful to call out more specifically that the goals regarding increased transplants have basis in reducing waitlist mortality, and asks the Executive Committee to consider this in framing the goals, objectives, and metrics. The Committee also sees clear lines between the proposed goals of the strategic plan and current project work, which is promising.

The Committee supports the plan, however, suggests re-working the goals, objectives, and metrics to include both equity and living donation to make it clear to Committees, the transplant community, and the public at large how the “foundations” of the OPTN will continue to be built upon and expanded. 

Region 7 | 03/18/2024

2 strongly support, 9 support, 1 neutral/abstain, 2 oppose, 0 strongly oppose 

Overall, members of the region are supportive of the proposed strategic plan, but with some opposition. One attendee noted that the plan has great large goals with are in line with the Patient Affairs Committee priorities. There is a need to tie measures of performance and measures of effectiveness that are quantifiable and are reviewed at pre-determined points in time, perhaps quarterly, to determine success. Another attendee noted that there needs to be clarification on how the community will be evaluated on the strategic plan initiatives. Another attendee agreed with including the proposed metrics as it is a great way to focus the discussion and shorten the Observe, Orient, Decide, and Act loop. Another attendee suggested that in addition to the business, operations and efficiency on the allocation and pre-transplant side, the OPTN should develop a strategic plan on what framework and infrastructure is needed to help improve the clinical outcomes and transplant longevity. Another attendee noted that increasing acceptance rates could be achieved by decreasing donor offers instead of increasing transplants, but this would be detrimental to the transplant community. Another attendee suggested that future iterations of the strategic plan needs to address recipient outcome data and initiatives. An attendee noted their concern with the strategic plan as they feel it does not contain a clear plan. Lastly, one attendee suggested that before educating patients on organ acceptance rates, patients need to have an introductory education on the transplant process. As there is a large knowledge gap amongst patients, starting with organ acceptance rates may be overwhelming and confusing.

OPTN Pancreas Transplantation Committee | 03/18/2024

The Pancreas Transplantation Committee thanks the OPTN Executive Committee for their efforts on the 2024 – 2027 Strategic Plan proposal.

The Committee is in support of this proposal and provided some feedback for consideration:

• There should be consideration of the use of artificial intelligence (AI). With the current climate, there is an increased burden on the human component of organ offers and the use of AI could potentially help with increasing efficiency and decreasing the work (burden) on the individual organ procurement organization (OPO) and transplant hospital staff. 
• Clarity on how the achievement of these goals will be measured would be helpful. Are there more numerical metrics that would be evaluated and if so, what would this look like for the goals outlined in the proposal?
• There was concern raised related to the increase in deceased donors over the years; the use of these organs (many of which are hard-to-place), which calls for concern in long-term outcomes. Risk adjustment metrics (i.e. KDPI) does not necessarily reflect the organs that are being accepted as previously stated; there should be some consideration in changing this outlook moving forward.

The Committee agreed with the OPTN Executive Committee’s plans on including the perspective from commercial payers and C-suite teams as it was felt the insight from these parties would be beneficial to these efforts.

The Committee also considered their current project, Continuous Distribution of Pancreata and how it could potentially be prioritized in the proposed Strategic Plan. The Committee agreed that some of the current efforts related to efficiency, such as offer filters, is reasonable to address first as it can improve current processes and complement the Continuous Distribution project.

Region 1 | 03/18/2024

0 strongly support, 9 support, 2 neutral/abstain, 1 oppose, 0 strongly oppose 

A member noted the absence of a specific goal around equity, especially with the findings of the National Academies of Sciences, Engineering, and Medicine (NASEM) report. The member was also concerned at omission of the work around continuous distribution, as this is currently a very large OPTN project that aims to provide more equitable organ allocation. The member stated that combining these components with the goals already in the plan would make it more complete. An attendee commented that the plan is missing any mention around living donation opportunities, which is important due to the current OPTN Living Donor Committee work in addressing long-term follow up and the collection of pre-referral data. A member agreed with the plan overall, but did stress that equity needs to be included. Two members agreed that equity must be included. An attendee suggested that the OPTN should be doing more with education of patients around listing and allocation, as many patients are confused with the allocation process and how the waiting list works. A member stated that it is challenging to review the strategic plan without the additional context of HRSA’s OPTN modernization initiative and how that might impact it.

OPTN Ad Hoc Multi Organ Transplantation Committee | 03/18/2024

The OPTN Ad Hoc Multi-Organ Transplantation Committee (MOT Committee) appreciates the opportunity to provide feedback on the OPTN Strategic Plan 2024-2027 (Draft Strategic Plan). 

The MOT Committee identified notable differences between the current Strategic Plan and the Draft Strategic Plan, especially in terms of the proposed goals. The Committee is concerned that the Draft Strategic Plan is narrow in scope. It notes that the proposed goals don't clearly align with important ongoing work, including MOT projects and continuous distribution, and questions how this work will be impacted if the Draft Strategic Plan is adopted in its current form. The MOT Committee is also concerned that the Draft Strategic Plan lacks granularity and the Committee supports inclusion of more details to support effective implementation. MOT Committee members note that there may be limited community support for proposed goal 1: improve offer acceptance rate, because offer acceptance is guided by patient needs. Members suggest that the Draft Strategic Plan incorporate greater focus on equity and living donation. They also suggested that the Draft Strategic Plan recognize that system improvements and innovations help build a sustainable environment for providers, in addition to serving patients. 

The MOT Committee is committed to ensuring that its projects enhance efficiency in organ allocation and to developing policies can be effectively operationalized.

American Society of Transplant Surgeons | 03/18/2024

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Society of Pediatric Liver Transplantation | 03/18/2024

The Society of Pediatric Liver Transplantation (SPLIT) appreciates the opportunity to comment on the proposed 2024-2027 OPTN Strategic plan. We have concerns that many of these goals, without having specific details attached, could result in decreased access to transplant for our vulnerable pediatric population. There is no specific mention of pediatrics anywhere in the proposed plan. We also feel that increased access and utilization of living donation should be part of the strategic plan. Finally, we call for addition of a pediatric-specific specialist to all committees including the Executive Committee to ensure our vulnerable patients are represented.

Steven Weitzen | 03/17/2024

I have a few concerns:

An overarching concern that I raised at two of the regional meetings -- once the modernization initiative continues to play out and contracts are entered into, what is to ensure that the goals set for the strategic plan will be adhered to? Because new leaders of OPTN may decide to do otherwise?

Another concern I have is that I would have wished there were more specific examples given as to how to effectuate the goals. Now, I understand we wish to have flexibility but it would have been nice to have some examples so we can see what is intended and also so we could attempt to steer OPTN in another direction if we disagreed.

I would have liked to see as goals:

a. to improve communication between transplant centers and transplant recipients, especially with respect to health crises (be it COVID or any other crises);

b. to improve understanding of the entire organ transplant process. There are too many people who have little or no idea of the "subway map", as oftentimes discussed by OPTN and SRTR -- and this impacts their ability to participate in organ transplant.

Region 5 | 03/15/2024

5 strongly support, 25 support, 1 neutral/abstain, 3 oppose, 0 strongly oppose 

Region 5 supported and appreciated the strategic plan presentation. An attendee suggested removing consent requirements for high KDPI kidneys and explained that the longer a candidate is on the wait list their preferences could change. An attendee suggested holding a national, public, campaign to help establish the goals to counter-balance negative media. A member institution said they support the initiatives to increase organs for transplant. They suggested changes in risk stratification for centers that accept marginal organs, so they are not overtly penalized for accepting such organs. An attendee asked if there has been progress in having centralized pathology (via digitalized images). They commented that the transplant field would benefit from an organ specific pathologist interpreting donor biopsy to reduce inter-observer availability and increase confidence to accept organs. In support of the current plan, an attendee suggested including information on how to achieve the goals with descriptions of interventions that will be implemented to meet the objectives and goals. A pediatric program supported the effort towards granularity and specificity, but noted there remains concern amongst the pediatric population that some of the transplant community's core values, such as equity and access, are not a focus of the proposed strategic plan.

OPTN Ad Hoc Disease Transmission Advisory Committee | 03/15/2024

The Ad Hoc Disease Transmission Advisory Committee appreciates the opportunity to comment on the OPTN Strategic Plan 2024-2027 proposal. The Committee supports the proposal and commends the effort to increase transparency for patients, but strongly encourages more attention to patient safety. While the proposed goals are appropriate, patient safety should remain paramount as transplant volume increases. There was uncertainty about how the emphasis on efficiency would impact the Committee’s ability to implement policy changes essential to improving patient outcomes. Members emphasized that the Committee’s work to streamline safety protocols ultimately improves efficiency, but not as outlined in this proposal. 

American Society of Transplantation | 03/15/2024

The American Society of Transplantation (AST) supports the overarching concepts encompassed in the 2024-2027 OPTN strategic plan but is concerned that most of the key strategic goals of the 2021-2024 strategic plan transition into components of the OPTN Vision without making clear how achieving the Vision will be accomplished as a result of the proposed strategic plan goals. Without this clarity, the goals proposed in the 2024-2027 OPTN strategic plan can be perceived as priority policy actions rather than strategic goals.

In addition, the AST also believes there are multiple key priorities that should receive more focus in the 2024-2027 OPTN strategic plan, including:

• Maintaining a focus on increasing the number of organ donors in addition to increased utilization and efficiency

• Increasing equity in all domains

• The importance of living donation

Without greater, more explicit focus on the components of the Vision and the above considerations, the AST is concerned that efforts to improve on these matters will be under supported and deprioritized over time. Other key considerations as the OPTN implements the 2024-2047 strategic are:

• Ensuring that patient outcomes aren't negatively impacted

• Ensuring safety including reducing donor disease transmission

• Ensuring that any enacted policies take into consideration availability of transplant center resources and do not create the opportunity for new punitive measures

Further, the proposed strategic plan Goal 1 and Goal 2 appear to have the greatest potential impact on renal transplantation. The plan would benefit from additional clarity on how appropriate tactics will be developed to address these issues in non-renal transplantation. Moreover, making progress on these two goals will require a clearer, data driven understanding of the root causes of variability in offer acceptance and utilization as an initial step. This information would then be used to prioritize development of new policies and drive implementation of the broad set of tools and strategies currently being considered (i.e., patient and transplant center education, patient involvement in decision making, offer filters, and predictive analytics). Additional feedback on Goals 1-3 as included in the proposal is provided below.

• Goal 1: Enhance Organ Acceptance Rates

-The goals are broad which allow specific objectives to be achieved while keeping in line with the strategic plan. This can also lead to uncertainty in creating granular plans with meaningful results. Increasing organ utilization without negatively impacting outcomes is a difficult objective to achieve and will require a more detailed review and evaluation than the metrics outlined. Organs at high risk of non-use such as those from donation after circulatory death (DCD) donors, high Kidney Donor Profile Index (KDPI) donors, and those with extended cold ischemic time need to be assessed carefully. It is not clear within the proposed strategic plan that the challenge of placing these organs will improve as many of the factors leading to difficulty with organ placement are not clearly understood and therefore not addressed.

-Addressing inefficiencies in organ acceptance begins with identification and articulation of the factors driving disparities between programs and regions. When looking at the reduction of organ non-use, the current allocation may represent a counter factor, with transportation of organs over further distances and costs associated with higher risk organs not accounted for. The development and deployment of incentive initiatives, creation of educational offerings to address gaps and standardize processes, and the collection of pre- and post-change metrics should all focus on the underlying factors.

-The plan proposes increased educational support for transplant programs, with an emphasis on monitoring the uptake of these educational resources. This initiative by the OPTN is commendable, potentially alleviating the need for transplant programs to develop their own materials; however, the merit of tracking educational resource utilization is questionable. This may lead to superficial compliance rather than genuine improvement and could impose additional burdens on some transplant programs.

• Goal 2: Optimize Organ Use

-The AST supports the initiative to work collaboratively with stakeholders to identify barriers to organ utilization, acknowledging specific challenges and variability in acceptance patterns across centers. It's vital to continue assessing outcomes for higher-risk organs to determine their optimal use. The AST suggests that exclusion from outcome measures be considered as a component of quality improvement projects intended to increase utilization of organs "at high risk for nonacceptance." Additionally, ensuring transparency in the allocation process when organs are offered out of sequence is essential and the reason each potential transplant recipient on the match run before the recipient is bypassed should be clearly identified and reported.

-The AST recommends that the OPTN work to develop a regulatory framework that establishes expectations that organ utilization will not be impacted by limits in access to operating rooms for transplantation, including dedicated operating rooms for transplant.

-The AST supports utilization of turndown data to develop evidence-based predictors of organs that are at "high risk for nonacceptance."

-While tracking access-to-transplant metrics is valuable, requiring transplant centers to report such metrics, which necessitate multiple data points, could be onerous. Alignment between HRSA, CMS, and transplant centers in data collection efforts is necessary to lessen this burden.

• Goal 3: Improve OPTN Efficiency

-The OPTN policy making process should be timelier when possible; however, there are concerns about expediting the policy development process at the cost of stakeholder involvement and an increased possibility of significant, unintended consequences. While efficiency is important, it should be secondary to achieving the other goals and without compromising the important and valuable rigor that is fundamental to OPTN policy development.

-The AST supports improving the time to implement policy as long as it is not achieved by systematically reducing the amount of time provided to transplant hospitals to prepare for implementation at their programs. It is very important that transplant hospitals are given the tools that they need and a sufficient amount of time to implement all policy changes.

-Stakeholder satisfaction is acceptable in principle, but more important is clinical outcomes. Also, the relevant stakeholders are not clearly identified.

-Data optimization is perhaps the most ambitious aspect of this goal, but limited detail is provided. From a diagnostic perspective, it would be educational to know how the varying components of the pre-transplant workup (e.g., NAT infectious panel, procurement biopsy, crossmatch, etc.) that contribute to organ utilization/acceptance or to other outcomes measures such as cold ischemic time. These components can then be a focus for process improvement.

Association of Organ Procurement Organizations | 03/14/2024

In regard to the OPTN proposed Strategic Plan 2024-2027, AOPO supports the goals of this plan to Improve Offer Acceptance Rate, Optimize Organ Use, and Enhance OPTN Efficiency. Each of these goals supports increasing transplantation and will positively build on the last decade of growth we have seen in the U.S. donation and transplantation system.

Missing from the plan was any mention of a strategy or consideration of how the OPTN may need to plan for the disruption that will occur with the mass OPO decertification in 2026. We encourage at least some brainstorming or future scenario planning that considers how the OPTN could support the ongoing operation of the national system if the CMS rules are executed as written.

Gift of Life Michigan | 03/14/2024

We appreciate the OPTN Executive Committee’s work to develop a strategic plan for transplantation through 2027.

We believe the draft plan broadly addresses important goals to increase transplants. We will be eager to see how the transplant ecosystem functions during the proposed changes to the OPTN Board and contractor relationship, and implore all parties involved to protect patients, donors, and transplantation while this transition occurs.

Goal 1: Improve Offer Acceptance Rate: Increase opportunities for transplants by enhancing offer acceptance.

One of the objectives for this goal is to develop and promote educational offerings for patients and centers about understanding offer acceptance. While we appreciate the desire to inform, we suggest that measuring the effectiveness of the learnings is as important as the quantity of distribution. In other words, do they convey the message in a way that viewers learn the content? Four of the metrics for this goal are associated with efficient organ offer acceptance, which we support. Organ offer acceptances (or declines) are highly complex exchanges that have grown more complex with broader organ sharing and seem to have created a level of chaos and confusion in managing the volumes. While we support measuring the time intervals the Committee suggests, we anticipate there is more to understand at a deeper level about this complex process, and that OPOs and transplant centers are just beginning to understand the impact of the changes to the system. The collaboration you mention under “enhancements to the strategic plan” remains critical to growing and maintaining a successful transplantation process.

Goal 2: Optimize Organ Use: Maximize the use of organs for transplantation for waitlisted patients, while maintaining or improving upon past equity gains.

We believe this goal addresses the current situation in which more organs are donated from more donors, but that more organs have not necessarily led to more transplants. With a goal of saving and restoring life and health to patients in end-stage organ failure, we note that understanding why relatively large numbers of organs are declined requires more study, appropriate capacity in the transplant centers to accommodate offers, realism about acceptable organs for a given patient, logistical challenges, and many other variables. While we appreciate the proposed metrics to reflect progress on the goal, we wonder whether they paint a clear picture. Do the proposed percentages provide insight, or do they simply count the number of events?

Goal 3: Enhance OPTN Efficiency: Increase the efficiency of the OPTN through improvement and innovation.

The stated objectives and metrics to support this goal, focused on streamlining the policy making process and more actionable data availability are worthwhile. We believe policy making has become cumbersome in part because while the OPTN’s members are largely seeking the same goal, the nuance and exceptions various parties believe are important often result in lengthy study, debate, modification, and compromise. We support your effort but ask that you be prepared for resistance to this change.

We believe the OPTN Board will face considerable challenges ahead, and urge all parties involved to be vigilant about the critical role the OPTN plays in facilitating efficient matching of donor organs to waiting patients, and to ensure that no one is denied a transplant because of inefficient leadership across the transplant continuum.

OPTN Patient Affairs Committee | 03/13/2024

The OPTN Patient Affairs Committee agrees that the overall goals of the strategic plan are aligned with the mission and vision of the OPTN but is concerned that the plan is far too vague and lacks specificity. The metrics need to be numeric and more information should be provided on how such metrics will be developed, monitored and tracked, with aspirational goals and related timelines of achievement. The metrics need to consider the current state and should be more granular so the OPTN can track if it is on target to achieve the goals within the 3-year time period, or if the OPTN needs to change course or readjust the plan if it is not on track to meet the goals. The Committee strongly recommends considering how living donation fits into the goal to increase opportunities for transplants, and that living donation should be an additive part of the plan. The Committee also recommends targeting a specific percentage decrease in the number of patients on the waiting list with a milestone date. Metrics concerning graft and patient survival across 1 year, 5 years, 10 years and beyond should be included in the strategic plan. The Committee would also like to see specific initiatives to increase transplants included in the plan, as well as initiatives to increase awareness, education, and patient engagement regarding the organ transplant process with all communities, but especially those who are underserved. The education of candidates on the risks and benefits of certain organs is directly tied to increasing organ offer acceptance rates. This empowers candidates to make the best decision for themselves. The Committee is also concerned by the lack of specificity regarding equity in transplant. The Committee also noted that this plan, and the goals within it, could be altered at the conclusion of the current OPTN contract; this should be identified in the plan as a significant risk factor. Additional feedback from Committee members is enclosed as an attachment.

View attachment from OPTN Patient Affairs Committee

Luke Preczewski | 03/12/2024

I would urge the board to include efficiency of the transplant system as a goal. We are at a crossroads in transplantation, with costs (specifically normothermic machine perfusion, increased flights, OPO SAC fees, complexity of cases, etc.) soaring, while payors have no appetite for increasing their reimbursement at the same rate. Well-intended policies are driving up costs to the point of non-sustainability. It is essential that future policy changes consider the cost to the system prior to implementation. All of the goals are noble, but without an assessment of system costs, they will overwhelm limited resources and decrease both the likelihood hospitals will want to operate transplant programs and the likelihood physicians choose transplantation as their specialty.

I am an employee of an OPTN member, but my comments are submitted on behalf of myself as a transplant professional, not on behalf of my employer nor any other organization.

Region 3 | 03/11/2024

3 strongly support, 11 support, 2 neutral/abstain, 0 oppose, 0 strongly oppose

Region 3 supported this proposal. During the discussion, several attendees recommended narrowing the focus of the plan and being more specific regarding the metrics of each goal. They added that implementing these strategies takes time and accounting for that will help with successful outcomes. Another attendee recommended reviewing projects that are in various stages of progress by committees to evaluate their alignment with the new strategic plan and engage committee discussion prior to tabling ongoing projects. 

American Society for Histocompatibility and Immunogenetics (ASHI) | 03/09/2024

The American Society for Histocompatibility (ASHI) and its National Clinical Affairs Committee (NCAC) appreciate the opportunity to provide feedback on the OPTN strategic plan. ASHI supports the Board’s proposed areas of strategic focus for 2024-2027. ASHI encourages more collaboration between OPTN and expert stakeholders such as ASHI and its members to refine current allocation schemes and develop innovative approaches for further improving clinical outcomes, transplant longevity, and reducing organ discards through more effective and efficient determination of donor-recipient histocompatibility.

Jef Kinney | 03/08/2024

I am writing to provide my perspective on the OPTN Strategic Plan. As a living donor kidney transplant recipient, I am forever grateful for the transplant process and my donor. AS I tell her, she saved my life. I am a proponent of living donor transplantation as it removes some of the concerns and operational and logistical issues associated with deceased donor transplantation and often offers a higher quality kidney.

Unfortunately, the strategic plan seems rather sparse regarding focus on and investment in the living donor process. As others have noted, specific goals and objectives related to living kidney donation would be helpful to help increase the focus on this source and increase participation. People are well aware of the option to be an organ donor when deceased through DMV license registration; however, I am not sure that the living donor option is well known and understood.

Thank you for considering my comments.

OPTN Vascularized Composite Allograft Transplantation Committee | 03/08/2024

The OPTN Vascularized Composite Allograft Committee thanks the OPTN Executive Committee for the opportunity to provide feedback on this proposal. The Committee does not have any feedback or concerns.

OPTN Operations and Safety Committee | 03/07/2024

The Operations and Safety Committee thanks the OPTN Executive Committee for their efforts on the 2024 – 2027 Strategic Plan proposal. The Committee is in support of the proposal and provided the following questions and feedback for consideration.

The Committee commented on the use of the terms “optimizing” and “maximizing” and that the terms being used interchangeably could be confusing and presents misunderstanding on the meaning of what is being proposed. There was a comment that from a transplant program perspective, there is nowhere in the plan that discusses cost and benefit and that transplant programs are disproportionately experiencing the cost side of the equation and seeing words like “maximize” can results in a negative reaction from this perspective. It was suggested that the term “optimize” was more favorable. Additionally, a turn of phrasing related to transplants is also important to note (and in being in alignment with the efforts by the OPTN Expeditious Task Force) – rather than saying more transplants, there should be consideration in rephrasing this to say more successful transplants. There is an opportunity to further evaluate practices that result in the growth of successful transplants that can present the opportunity for best practices being shared and modeled.

The Committee asked if there were any conversations related to offer filters. The delay OPOs see from getting things into the OPTN Donor Data and Matching System for data fields is With programs using normothermic regional perfusion (NRP), it seems like there is quite a delay for a simple data field that results in programs filtering off by accident, which is significant. It should not be this way and there should be consideration in adding data to the OPTN Donor Data and Matching System in a more timely manner.

The Committee voiced agreement that there needs to be data, agreement with stakeholders, and transparency with the community to come to a common goal of making these processes better.

OPTN Living Donor Committee | 03/07/2024

The OPTN Living Donor Committee appreciates the opportunity to provide feedback on the proposed strategic plan. The Committee agrees with the importance of the three proposed goals, but noted some concern for the lack of goals and objectives specifically related to living donation. Specifically, members explained that it may be difficult to achieve the Committee’s charge under the proposed strategic plan and that approval of projects related to living donation may be limited considering how the OPTN Policy Oversight Committee weighs and scores projects for approval based on alignment with the strategic plan. While the Committee appreciates that the OPTN Executive Committee considers the safety, protection, and follow-up of living donors as “foundational” to the OPTN, it is challenging to see how “foundational work” would be prioritized under the proposed strategic plan. 

The Committee recommends that the OPTN Executive Committee consider adding objectives and metrics within the proposed goals to address living donation. Specifically, the Committee recommends that Objective 1 under the “improve offer acceptance rate” goal be modified to be more specific to “offer acceptance from deceased donors and improved utilization from living donors” Also, the OPTN Executive Committee should consider adding an objective about enhancing living donation under the “optimizing organ usage” goal, given the recent request for the Committee to evaluate how the OPTN can enhance living donation moving forward. Finally, the Committee recommends modifying or adding metrics underneath each goal to address living donation and define specifically how the OPTN will know it is succeeding in this fundamental area. In particular, the Committee recommends metrics addressing equity and outcomes in living donation. 

The Committee also discussed how their current project, a Collaborative Approach to Living Donor Data Collection, fits in to the proposed strategic plan. The Committee explained that the effort fits well into efficiency, noting that the project will reduce redundancy, streamline data collection, and provide additional data to inform long-term outcomes to promote efficiency long-term. Increased knowledge of living donor outcomes promotes living donation, which then in turn promotes efficiency by bringing more organs into the system and maximizing use of organs. The Committee underscores the importance of analyzing and collecting data on living donor candidates, long term outcomes for living donors, and improving data collection processes within the OPTN as helping to achieve the goals of promoting equity, efficiency, and enhancement of living donation, and advocates for including more specific outcomes and metrics related to these important aspects in the strategic plan. 

Region 8 | 03/05/2024

2 strongly support, 12 support, 3 neutral/abstain, 0 oppose, 0 strongly oppose

Region 8 supported the Strategic Plan and offered several suggestions. A member suggested a living donor goal and a patient outcome post-transplant goal. Another attendee commented that there should be objective and specific goals regarding living donation. The objectives of the goal should be improving the quantity and quality of data available to prospective living donors, the health & safety- both short-term and long-term, protection from financial and insurance-related impacts of their donations, and both long-term post donation follow-up of living donors. They explained that these are not stated metrics but hope patient and graft survival metrics will be included while implementing the goals stated in the Strategic Plan. While focusing on increasing acceptance rates, decreasing organ non-use and increasing transplants can be measured in real time. The member believed the Strategic Plan should do more to help improve the overall system. Another inquired as to what impact will the goals have on patient and graft survival both short and long term. They pointed out that honoring the donor's gift doesn't stop when that organs are transplanted, it continues through the entire life of the recipient. An institution asked to see a focus on maximizing the utilization of potentially usable organs, not just those for which OPOs have obtained consent. Another attendee suggested the OPTN incorporate SMART goals for the Strategic Plan.

Region 2 | 02/29/2024

4 strongly support, 13 support, 3 neutral/abstain, 1 oppose, 0 strongly oppose

Members of the region support the proposed strategic plan. It was noted that the plan has identified great areas of focus. While there was support for increasing the number of transplants over the coming years, one attendee highlighted the need for increased infrastructure outside of the OPTN’s purview to support this goal. In order to achieve more transplants, there will need to be more hospital beds, ancillary services, ease of access to medications, and combating medication shortages, to name a few. Another attendee noted their support of the plan, but there is a need to define the ethical responsibility to have discussions with transplant candidates when accepting marginal organs. Additionally, there needs to be an OPO standard to provide basic required testing in order for transplant programs to make informed decisions. One attendee did note their opposition to the proposed strategic plan as there is a poor balance between equity and utility.

Region 11 | 02/29/2024

2 strongly support, 12 support, 3 neutral/abstain, 0 oppose, 1 strongly oppose 

The region overall supports this proposal. One attendee commented that in their professional experience, objectives may not always be aligned with vision. A member stated that offer acceptance should be removed as a metric because that would allow centers to decline an offer, versus putting in a provisional yes just to see if the organ gets accepted by a center ahead of them. The member believes that by removing offer acceptance, allocation will speed up and increase utilization because offers will go to centers that will accept them. An attendee remarked that with the significant focus on offer acceptance, the OPTN should have a similar focus on fixing issues with allocation and system inefficiencies. Another member suggested that long term outcomes of transplants is important, and that doing transplants but not being able to provide care of these organs is not a good practice. They added that there are significant work force issues in transplant, especially with transplant nephrology, that need attention. One attendee recommended that the OPTN provide feedback to transplant centers that turn down donors with the organ offer refusal code “DCD donor neurological function/not expected to arrest” so they know when there are instances where the donor did progress.  

OPTN Heart Transplantation Committee | 02/28/2024

The OPTN Heart Transplantation Committee thanks the OPTN Executive Committee for presenting the Strategic Plan 2024 – 2027 proposal during the Committee’s February 7, 2024 meeting. The Committee members expressed their concerns about the potential impact the change in strategic goals might have on their development of a continuous distribution of hearts allocation framework. Several members said that while increasing the number of transplants is not the sole priority of the project, there are many aspects of the framework being developed that will likely result in more transplants, for instance, improving the system’s efficiency should positively impact transplants overall. In addition, members pointed to the substantial influence a heart transplant program’s mortality rates have on the program’s overall performance metrics. It was stated that heart transplant programs are going to remain reluctant to transplanting so-called ‘marginal donor hearts’ as long as the use of such donor hearts counts the same when measuring performance as does the transplant of a non-marginal donor heart. Better differentiating mortality based on the role of the transplant program in terms of patient management, might help encourage greater use of marginal donor hearts. More use of expected versus observed mortality might result in a more flexible way of considering mortality that could address some of the Committee’s concerns. Additionally, evolving how the OPTN defines key aspects of Donation after Cardiac Death (DCD) might result in the increased use of such donor hearts.

OPTN Histocompatibility Committee | 02/27/2024

The OPTN Histocompatibility Committee appreciates the work the OPTN Executive Committee has put into development of the 2024-2027 OPTN Strategic Plan. The Histocompatibility Committee wants to ensure that necessary operational work is able to continue, such as alignment with other regulators. The Committee also wants to clarify how this plan may impact work already underway, and how the plan would be operationalized and other necessary work would be able to continue to be accomplished.

OPTN Pediatric Transplantation Committee | 02/27/2024

The Pediatric Committee has some very serious concerns about this strategic plan and the direction it would take the OPTN. The proposed strategic plan does not take equity into account in any of the proposed goals or objectives. In recent years the transplant system in this country has made progress in equity, and excluding equity from the new strategic plan puts that progress at risk. The policy evaluation process needs to be clearly defined. The current evaluation model used by the OPTN Policy Oversight Committee accounts for proposals that do not have impact across the transplant system but will greatly impact smaller population of candidates. This is critical to patient populations like pediatrics whose raw numbers may be small when compared to adult patient populations, but every policy change that increases adult access to organs limits pediatric access to organs. Pediatric policy proposals are often related to equity and not efficiency. Will proposals that increase the pediatric population’s access to organs be allowed under this plan, or would those proposals not be approved for public comment because they do not neatly fit into this strategic plan? Projects that would increase the likelihood of pediatric candidates being matched to pediatric donors have already been delayed in favor of proposals focusing on efficiency. The Committee feels strongly that a performance metric that is based on successful transplant outcomes should be included. While reducing non-use and increasing utilization is important, ensuring that patients who receive lifesaving transplants are able to live longer, healthier lives is equally important but is entirely left out of this strategic plan. The goals and objectives listed within this plan overlap, and the plan is ambiguous in informing the transplant community what policies or proposals would not fit within its parameters. Moving forward, the Committee asks the Executive Committee to assign a pediatric specialist, not a physician who treats both adults and children, to all committees to ensure pediatric candidates are not left behind in over the next three years.

UAMS | 02/27/2024

Based on an evaluation of the proposed OPTN Strategic Plan for 2024-2027, We believe the proposed changes and goals have the potential to have a positive impact on our patient population and transplant center. We believe with the correct utilization and support; progress can be made toward reaching the outlined goals. To provide additional guidance and clarification to transplant programs, we believe more specific metrics related to organ offer acceptance rate and optimization of organ use would be beneficial. Instead of a broad increase in organ offer acceptance and decrease in organs recovered but not transplanted, a specific percent decrease/increase would clarify what level of action and what resources may be needed to reach that goal. In addition to more specific metrics, we believe the plan could provide strategies for implementation of the outlined goals that would make it easier to see the anticipated outcomes and begin creating a positive change.

Region 4 | 02/26/2024

2 strongly support, 10 support, 2 neutral/abstain, 0 oppose, 0 strongly oppose

Region 4 supported this proposal. One attendee said it will be important to ensure that the goals in the strategic plan are adhered to during the modernization initiative. They added that this will be important if there are multiple vendors and contracts.

OPTN Liver & Intestinal Organ Transplantation Committee | 02/26/2024

The OPTN Liver & Intestinal Organ Transplantation Committee thanks the OPTN Executive Committee for their efforts on the OPTN Strategic Plan 2024 – 2027 proposal.

While the Committee supports the effort towards granularity and specificity, there remains concern that some of the transplant community’s core values, such as equity and access, are not a focus of the proposed strategic plan. Equity and access have been the priority of the transplant community’s work for several years and the Committee suggests that the OPTN Executive Committee incorporate specific language to address these key values.

The Committee notes the lack of mention of the continuous distribution projects which were delegated to the organ-specific committees as a priority project. The Committee seeks reassurance that the development of continuous distribution will remain a priority with appropriate resources allocated in order to develop such a large, impactful project. The Committee notes that they have efficiency improvements within the preliminary framework of continuous distribution.

There is concern that any top-down approach to project prioritization will result in a lack of input from all stakeholders, especially from minority and under-served populations. For example, any consideration of mandatory filters should engage all stakeholders in decision-making. The Committee suggests that metrics should be developed and monitored for all stakeholders in order to ensure the system is functioning properly. These metrics should be able to be collected across time and contractors in order to have valuable data for monitoring. The Committee also suggests the development of a mechanism that would allow for more direct feedback.

Regarding each strategic plan goal, the Committee expresses concern that the stated first goal, improve offer acceptance rate, is a metric. The Committee finds this troublesome because it can represent a reflection of transplant program behavior which does not drive access to or increase in transplant. The Committee notes that to improve organ offer acceptance, one could try to place organs at high volume transplant programs that will accept the organ, however that is not fair and could be dangerous for the system in regard to equity and access. The Committee supports the substance of the second goal, optimize organ use. For the third goal, enhance OPTN efficiency, the Committee also has concerns as it refers to the operations of the organization rather than detailing important concepts like access. The Committee emphasizes that the goals focused on efficiency should not sacrifice patient outcomes. The Committee also recommends that the goals should be more specific and updated to specific, measurable, achievable, relevant, and time-bound (SMART) goals.

The Committee concluded that they interpret this strategic plan to be an operational document rather than a strategic document about key values in the field of transplantation. The Committee emphasizes that a strategic plan should be the latter in order to support the governing body of transplantation as a national effort.

OPTN Transplant Coordinators Committee | 02/23/2024

The Transplant Coordinators Committee appreciates the opportunity to hear and respond to the Executive Committee’s proposed 2024-2027 OPTN Strategic Plan. Members expressed appreciation for the clarity and actionability of the written plan, noting the clear direction it provides, especially related to potential projects.

Members voiced support for the focus on successful transplants as an area for improvement, while recognizing that the definition of success can be subjective from patient to patient. Members highlighted an opportunity to modernize the system and ease burden on overtaxed transplant coordinators by streamlining the organ listing process.

In all, the 2024-2027 OPTN Strategic Plan received strong support. Members agreed there is clear alignment around issues like improving processes. Execution will require collaboration between committees, government bodies, OPOs and individual centers - but the will seems strong to drive meaningful progress.

Robert Goodman | 02/22/2024

At the same time that I completely agree with the goals of the plan, I can see why some say it is not specific enough. I happen to disagree with that statement in that the transplant community can weigh in on those metrics to help make them more meaningful. If the OPTN spoon feeds the metrics to the transplant community, that will generate a different set of disagreements. I think the approach being suggested is more collaborative, but more specificity as to how that feedback and input will come about needs to be addressed.

Anonymous | 02/08/2024

There is not enough granularity to know what this means or how they plan to enact. We cannot increase transplants in isolation. Restrictive post transplant survival expectations, insurance plan COE, public reporting - have all pushed programs to attempt to mitigate risk by cherry picking donors. Only with relief of these measures can programs increase risk taking on donor side.

John Sperzel | 02/05/2024

I support the OPTN Strategic Plan 2024-2027, including the three goals (1. Improve offer acceptance rate, 2. Optimize organ use, and 3. Enhance OPTN efficiency).

I believe the Strategic Plan could be improved by including more specific metrics (e.g., instead of stating "increased offer acceptance rates," I would suggest "to increase the offer acceptance rate by __%")

Déboralis Ramos | 01/31/2024

Strongly Support

Neeraj Sinha | 01/29/2024

I support the proposed strategic plan, but I would make a pitch for adding 'incorporation of big data and artificial intelligence (AI) to advance OPTN goals' as a strategic priority.

Data pipeline needs to be substantially updated and broadened. We tend to over-emphasize the member burden and often consider member burden as a prohibitive factor rather than as a manageable factor. We tend to be rather slow in incorporating new and relevant data elements, indeed often we never get around to incorporate them. To give just a few examples in lung transplant: Aspects of coronary artery disease, esophageal dysmotility, and frailty have been known to increase post-transplant risk for last many decades, but we still have to rely on single- or small multi-center data for our clinical decision making, whether selection or post-transplant management. A larger OPTN-wide database with relevant data elements would more accurately uncover trends and associations and better guide clinical decision-making. The impact in terms of saving lives and improving allocation could be rather large with this approach.

With regard to managing data burden, considerations would be developing efficient data collection processes like having ability to perform automated data extraction from EMRs into TEIDI forms, use of secure portals for patient self-reporting (for patient reported outcomes), and a cost-benefit analysis of adding personnel for increased data reporting burden with added cost shared by payers.

Carle Porter | 01/29/2024

Full transparency is needed significantly more than it is now. From my experience there isn't any. The last thing a patient should be told is 'well we have no answers for you' that is unacceptable! All this talking and things still move at this glacial pace. More awareness should be raised by your organization publicly not just on your websites. Commercials, billboards, etc. None of this should be a secret to the world. Stop talking about things that 'might' happen and just implement things. We live in the most advanced age in human history and for transplant to not be better than 'well we don't know'!? Is unfair to us as human beings. You 'plan' and we suffer, we die waiting. My suggestion, stop quietly promoting your 'strategy' just in a community that already knows all this. I have very little faith in any of this because your organization has not put faith in me that anything will ever happen that will make a difference TODAY, not 2027, not 2030, NOW. The people have no trust in you. There's needs to be better utilization of donor kidneys for those who don't have living donor. I would suggest actual patient testimonials and not just talking heads that will agree with the program of what you want them to say. Something else that would compliment this would be better trained staff Transplant Coordinators and representatives of this field. Not just those emotionless machines that treat us like cattle. If you have 'big plans' then do what you say you're going to do if not than this is just a waste of everyone's time. Make things better for EVERYONE no more excuses. CHANGE THE CULTURE. But do I know? You aren't even going to read this anyway.

Anonymous | 01/24/2024

These are all lofty goals, with associated metrics, that I assume will receive strong support. What I don't see in the plan are the actual strategies for implementing these goals, which makes it difficult to evaluate the plan. I would also find it important to include information from the preceding 3-year plan: what were those goals? how successful (or not) were they achieved? and what was learned from that plan to inform this plan?

Anonymous | 01/24/2024

Support