CMS expects a later start date for the mandatory payment model for organ transplants

The Centers for Medicare & Medicaid Services recently announced that they expect a later start date for the Increasing Organ Transplant Access Model. The agency stated that it “continues to work on the final rule and therefore anticipates a later start date for the model than the proposed start date of January 1, 2025.” The mandatory payment model would test whether performance-based incentive payments paid to or owed by participating kidney transplant hospitals would increase access to kidney transplants while maintaining or improving the quality of care and reducing Medicare spending. In July, the AHA told the Center for Medicare and Medicaid Innovation that the IOTA model would needlessly disrupt and confuse the transplant ecosystem, potentially incentivize subpar matches given its heavy emphasis on volume, and conflict with other regulatory requirements would.

“A complex (not to mention successful) implementation of a payment model requires significant time, resources, and personnel from hospital participants,” the AHA wrote. “But CMMI has proposed an IOTA launch date of January 1, 2025 – less than six months in the future and an even shorter period from when the rule will be in its final form. This would leave participants with equally little information about their mandatory participation.” Given the transformation of the organ transplant system noted above, this aggressive timeline is unsustainable.