COVID-19: Effect on Organ Donation and
Updated June 17, 2020
The U.S. domestic response to Coronavirus Disease 2019 (COVID-19)
poses both short- and long-term
concerns for the U.S. organ transplant system. Organs are a limited resource,
and their allocation is
strictly regulated to try to ensure that no donated organs go unused. A number of transplant centers have
suspended their transplant programs
due to COVID-19. In addition, individuals were inactivated from
in large numbers due to COVID-19 precautions, and inactivation may occur again if states
have to halt elective procedures due to COVID-19 surges. D
isruptions in the system may create long-term
effects for both the allocation of organs and the viability of involved organizations, which are subject to
federal outcome measures.
This Insight provides background information on the organ donation and transplantation system,
summarizes action taken to respond to COVID-19 by the organ transplant community, and identifies
potential issues for Congress.
Organ donations and transplantations are coordinated through the Organ Procurement and Transplantation
Network (OPTN), a
nationwide network of all organizations involved in the process (e.g., transplant
centers, organ procurement organizations
OPTN is administered by the United
Network for Organ Sharing
(UNOS), a private organization under contract with the Department of Health
and Human Services (HHS) Health Resources and Services Administration (HRSA). UNOS has held the
contract to administer OPTN since it was established by the National Organ Transplant Act of 1984 (P.L.
OPTN administers a series of policies
designed to allocate organs with consideration of both the limited
number of organs and their short shelf-life, am
ong other considerations. OPTN is also responsible for monitoring performance of OPTN members.
OPTN is able to take emergency action
in the event that a
policy proposal is required due to an emergent public health issue or patient safety factors. Policy
proposals under emergency action must be submitted through the normal policy proposal process,
they are subject to a truncated comment period and carry an expiration date.
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Prepared for Members and
Committees of Congress
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In addition, the Centers for Medicare & Medicaid Services (CMS) plays a role in oversight of OPOs by
requiring conditions for coverage in order to receive payment for activities under Medicare and Medicaid. (42 C.F.R. §§486.301-486.360).
Those conditions include outcome metrics, such as donor recovery rates
and donor yield, which OPOs must meet in order to be recertified.
UNOS first responded on March 18, 2020,
by implementing specific codes to indicate if a transplant
candidate inactivates from an organ waitlist due to COVID-19 precautions, allowing transplant programs
to inactivate their entire waitlist if the program closes, and issuing organ retrieval guidance to OPOs.
Since that date, UNOS has issued guidance
periodically to all affected individuals and organizations.
Actions to respond to COVID-19 can be placed in three categories: (1) affecting transplant programs, (2)
affecting OPOs, and (3) affecting transplant patient safety.
UNOS is allowing transplant programs to inactivate their entire waitlist
while associated health systems
are responding to the COVID-19 pandemic. Ultimately, reducing transplant capacity is a decision made
by the transplant center or the associated health system. This may become necessary as many hospital
resources are stretched thin responding to the COVID-19 pandemic, to protect transplant patients from
contracting COVID-19, and as fewer donor organs become available. On March 23, 2020, a team of
transplant surgeons published guidelines for a phased approach to reducing transplant activity
pandemic that begins with a 25% reduction (e.g., no living donors) and progresses to a complete stop of
all new transplant activity in the event that a health system is overwhelmed.
UNOS also issued guidance for reactivation of waitlists for liver transplant candidates and kidney
The new guidance allows transplant candidates to reenter waitlists without being
subject to additional clinical testing that would normally be required.
Organ Procurement Organizations
OPOs are being encouraged to recover organs locally whenever possible.
Under normal circumstances,
the transplant team may travel to a hospital where a donor is located in order to perform surgery to
recover organs. The UNOS guidance, with support from the donation and transplant community, i
recommending that surgeons within the donor hospital conduct the recovery surgery whenever possible.
This guidance is intended to prevent infection among transplant teams, thereby facilitating the
continuation of organ transplants.
Transplant Patient Safety
Transplant recipients are generally considered high risk for developing illnesses due to a suppressed
immune response. After transplantation, patients are prescribed anti-rejection medications that are to
suppress the immune system for the remainder of their lives.
OPTN amended a number of policies to help protect patient safety by minimizing exposure risk to the
Allowing transplant programs to maintain waitlist priority for patients who cannot
undergo routine testing due to the COVID-19 pandemic. This allows individuals to
prioritize safety by forgoing entering a medical facility (OPTN Policy 1.4.F)
Allowing waitlist priority to apply retroactively to certain patients who cannot obtain
required routine pre-transplant testing (OPTN Policy 3.7.D)
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Relaxing transplant follow-up data requirements to prevent unnecessary exposure to the
COVID-19 virus (OPTN Policies 18.1, 18.2, 18.5.A, and 18.5.B)
In addition, OPTN requires COVID-19 test reporting for deceased donors.
Transplant centers are able to
see whether a donor was tested for COVID-19 and the results of the test. The criteria are intended to limit
the possibility of transmission of the COVID-19 virus to a transplant recipient through transplantation.
Issues for Congress
Current disruptions in the organ transplant system may have long-lasting effects as individuals and
transplant centers postpone lifesaving surgeries in order to mitigate exposure to the COVID-19 virus. The
number of transplants performed per week
and the number of deceased donors recovered per week
decreased considerably at the start of the COVID-19 pandemic, although the numbers are now increasing.
This activity decrease may affect performance reviews for some transplant centers and OPOs. OPTN has
indicated that it is working to make changes to its outcomes metrics. On March 17, 2020, the Association
of Organ Procurement Organizations
issued a letter to the Trump Administration requesting a change to
the outcome measures.
This request was issued shortly after OPTN came under scrutiny from Congress
for poor OPO performance. CMS has not yet indicated whether any changes would be made to the
outcome measures required for recertification of OPOs in response to the COVID-19 pandemic. However,
in December 2019, CMS proposed a new rule
that would revise outcome measures to make them stricter.
Under the proposed rule, based on most recent performance data, many OPOs would not meet the
measures required to be recertified.
Jared S. Sussman
Analyst in Health Policy
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