1CMS Proposed Rule Would Overhaul OPO Oversight - Comments Due March 31
CMS published a proposed rule on January 30 that would significantly revise the Conditions for Coverage for OPOs. Key changes include new QAPI requirements for medically complex organs and donors, revised designation requirements, clearer rules for when a service area is open for competition, and an updated appeals process.The rule also aims to define and deter unsafe practices while maximizing organ utilization. Public comments are due by March 31, 2026 - this is the window for OPO leaders and staff to weigh in on rules that will directly shape how your organization is evaluated and potentially competed.
On your shift: The medically complex organ language matters for your workflow. CMS wants OPOs building QAPI programs specifically around these cases - which means how you evaluate, manage, and document expanded-criteria and DCD donors is about to get more structured. If your OPO’s quality team hasn’t started talking about this, they will be. Comments are due March 31.
Source: Federal Register
2Nevada Donor Network to Take Over South Florida After Historic LAORA Decertification
Following the first-ever mid-cycle decertification of an OPO - Life Alliance Organ Recovery Agency (LAORA), a division of the University of Miami Health System - CMS has approved Nevada Donor Network to assume organ procurement services for the Southern Florida Donation Service Area. The region spans 7 million people across six South Florida counties and the Bahamas.LAORA was decertified in September 2025 after investigators found years of unsafe practices, poor training, chronic understaffing, and paperwork errors. Staffing shortfalls alone may have caused as many as eight missed organ recoveries per week. Nevada Donor Network, which has strengthened from a historically underperforming OPO into one of the country’s top performers, will transition services with CMS oversight including joint handoff meetings.
On your shift: If you work in South Florida or Nevada, this directly affects your team. NDN is going to be hiring - a lot - to staff a second DSA 2,300 miles from home base. If you’re a traveling coordinator or considering relocation, watch for NDN postings in the Miami-Dade and Broward area. For the rest of the industry: this is the precedent. CMS proved it will decertify and reassign. Every OPO’s compliance team is paying attention.
Source: CMS.gov
3Congressional Investigation Targets Foreign Nationals on U.S. Transplant Waitlists
Ways and Means Committee Chairman Jason Smith and Oversight Subcommittee Chairman David Schweikert have demanded documents from the University of Chicago Medical Center and Montefiore Medical Center over reports that wealthy foreign recipients are jumping the U.S. organ transplant waiting list at these tax-exempt institutions.The investigation has already contributed to the Trump Administration’s decision to decertify LAORA in Miami. OPOs should be aware of the increased political scrutiny around transplant equity - a trend that is likely to intensify ahead of the 2026 recertification cycle.
On your shift: You probably won’t feel this one on your next case, but the political environment around transplant equity is shifting fast. If your OPO works with transplant centers that have significant international patient populations, expect more documentation requests and compliance attention. The broader signal: Congress is watching the system more closely than it has in years.
Source: Ways and Means Committee
449,064 Transplants in 2025 - Can OPOs Reach the 50k Goal This Year?
The U.S. performed 49,064 organ transplants in 2025, according to UNOS, keeping AOPO’s ambitious 50,000 transplants by 2026 campaign tantalizingly within reach. Liver transplants hit a record 12,344 (up ~8% year-over-year), and living donation grew 3% to 7,237 donors.Kidney transplants dipped slightly (27,573, down 102 from 2024), and over 103,000 patients remain on the national waitlist - more than 90,000 of them waiting for a kidney. With 936 more transplants needed to cross the 50k threshold, every recovered organ matters.
On your shift: 936 transplants is the gap. That’s fewer than 20 per OPO if spread evenly - which it won’t be, but the math says it’s achievable. The kidney dip is the number to watch. If your OPO is tracking toward recertification metrics, the kidney consent numbers are what CMS will scrutinize. Every authorization conversation and every referral follow-up counts more this year than last.
Source: UNOS
5OPTN Announces Monthly Reviews to Crack Down on Out-of-Sequence Allocations
OPTN and HRSA announced a change to monthly routine allocation reviews to address the growing problem of organs allocated out of OPTN sequence (AOOS). The rate of AOOS has accelerated sharply - from about 1 in 45 transplanted organs in 2018 to roughly 1 in 5 by 2024.The AOOS Workgroup is developing proposals including a formal administrative definition of an \"offer,\" an expedited protocol for hard-to-place kidneys, and compliance improvement measures. For OPO coordinators, this means tighter documentation requirements and more scrutiny on how organs are matched and placed.
On your shift: If you’ve ever placed a kidney out of sequence because the match run wasn’t moving and the organ was declining, this affects you directly. OPTN is moving toward monthly review of every AOOS case. Document everything - the clinical rationale, the timeline, which centers declined and why. The expedited protocol for hard-to-place kidneys could actually help, but until it’s finalized, the compliance lens is tightening.
Source: HRSA