OPTN Proposal and Comment Portal
The OPTN Liver and Intestine Transplantation Committee has posted their new liver allocation proposal and it can be found here.
Summary of Proposal:
- OPTN has proposed a concentric circle model (referred to as B2C 32) that favors patients within 150 miles of the donor hospital.
- The MELD cutoff for broader sharing is 32.
The comment portal is live here and will remain open until November 1.
- What MELD sharing threshold do you recommend?- Leave blank. Responsive commentary provided below
- Do you recommend that the fixed sizes of the circles be larger, smaller or remain the same? - Larger
- Please indicate your preference for each of the below models
- Broader 2 Circle: - strongly oppose
- Acuity 250+500: - strongly support
- As HRSA’s July 31, 2018, letter to OPTN makes clear, the National Organ Transplant Act (NOTA) and implementing Final Rule require OPTN to establish a “nationwide distribution of organs equitably among transplant patients.”
- While the existing regions and DSAs clearly violate this requirement, simply removing them and replacing them with a scheme that yields a similar result still violates NOTA. Where transplant patients live cannot be the basis for liver allocation unless specifically “required” by NOTA’s narrow exceptions.
- The Final Rule requires distribution of organs “over as broad a geographic area as feasible.”
- While many transplant centers prefer the inequitable and unlawful status quo, HRSA’s letter makes very clear that “consensus is not required under the OPTN final rule and should not be a barrier to adopting a liver allocation policy that complies with the OPTN final rule.”
- Because it is founded in a geographic construct, the B2C model clearly contravenes NOTA and will necessitate HRSA intervention if adopted by OPTN.
- With regard to the MELD cut-off, we believe that any restriction above 15 is unwarranted and contradictory to NOTA and the Final Rule.
- The Acuity model, while imperfect, is oriented in patient need, likely complies with NOTA, and is a firm foundation for achieving the goals of NOTA and the Final Rule.