MEETING SUMMARY Region 1 Meeting March 2, 2015 An OPTN/UNOS Region 1 meeting was held on March 2, 2015 at the Beechwood Hotel in Worcester, MA. Dr. Heung Bae Kim, Region 1 Councillor, convened the business meeting and welcomed those in attendance. There were 62 individuals in attendance representing 79 percent of UNOS institutional voting members. Those members present unanimously approved the November 3, 2014 regional meeting summary. OPTN/UNOS Update Dr. Heung Bae Kim, Region 1 Councillor, provided the OPTN/UNOS Update which included the following information: OPTN and UNOS Strategic Planning o Updating 2012 Strategic Plan Clarified goal #2, access to transplant Broadened goal #3, survival goal Combined patient and living donor safety goals o Planning for 2015-2018 Member review of proposed plan – spring 2015 Board review and approval – June 2015 KAS Implementation Update o “Out of the Gate” Data Monthly monitoring reports posted to OPTN wesbite Redesigning Liver Distribution o Further refining the metrics of access, disparity and ways to optimize distribution o Identify financial implications of alternative sharing methods o Address transportation and logistical issues o Public Forum June 2015 IT Projects Nearing Completion New public comment tool on OPTN website o Blog-style public comment Promote trust and transparency Publish all comments received Non-Discussion Agenda **Proposals not presented or discussed Proposal to Improve UNetsm Reporting of Aborted Procedures and Non-Transplanted Organs (Living Donor Committee) This proposal is intended to clarify and simplify reporting requirements for aborted living donor recovery procedures and incidents when a living donor organ is recovered but not transplanted and to ensure that follow-up forms are generated so no living donor is lost to follow-up. Region 1 Vote: 12 yes, 0 no, 0 abstentions This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: Pending implementation and notice to members Clarify Policy Language and Process for Individual Wait Time Transfer (Patient Affairs Committee) Policy 3.6.C: Waiting Time Transfer does not completely and accurately describe the process that occurs when a candidate transfers primary waiting time from one transplant program to another. The Patient Affairs Committee (hereafter, the Committee) proposes modifications to Policy 3.6.C so that it details the current process and defines waiting time that is eligible for transfer. This proposal promotes the efficient management of the OPTN by describing the responsibilities of both transplant programs and the OPTN Contractor in the individual waiting time transfer process. By defining waiting time that is eligible for transfer, this proposal also ensures that the waiting time transfer calculations are accurate and that the process is fair for all candidates. Region 1 Vote: 12 yes, 0 no, 0 abstentions This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: September 1, 2015 Proposal to Collect Ex Vivo Lung Perfusion (EVLP) Data for Transplant Recipients (Thoracic Organ Transplantation Committee) Ex vivo lung perfusion (EVLP) is an emerging technology that can be used during transport, and to preserve and condition lungs prior to transplantation. The utilization of EVLP is not currently reported to the OPTN, so the OPTN cannot determine how many lungs have been perfused or transplanted. In the spring of 2015, the OPTN will implement changes to the OPTN Tiedi forms, including the Deceased Donor Registration form (DDR). Through the modified DDR, Organ Procurement Organizations (OPOs) will report whether an accepting transplant program intends to perfuse the lungs prior to transplant. However, there is no corresponding field on the Transplant Recipient Registration form (TRR) for transplant programs to report whether lungs were perfused prior to transplant. The Thoracic Committee believes it is important to capture this information to monitor lung allocation, recipient safety, and organ and patient outcomes. This information will also be important for future policy development and risk adjustment for member-specific performance measures. Region 1 Vote: 12 yes, 0 no, 0 abstentions This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: Pending implementation and notice to members Discussion Agenda Operations and Safety Committee Proposed ABO Blood Type Determination, Reporting, and Verification Policy Modifications This proposal seeks to: 1. Clarify requirements related to ABO blood type determination, reporting, and verification for donors and candidates 2. Strengthen current key system safety components to ensure the correct organ is transplanted into the correct recipient and that the match is ABO compatible or planned incompatible 3. Align OPTN/UNOS and Centers for Medicaid and Medicare Services (CMS) blood type requirements more closely This proposal was originally released in the spring 2014 public comment cycle and has been modified to address concerns raised by the transplant community. Region 1 Vote: 11 yes, 3 no, 0 abstentions Comments: The region approved the proposal with a comment that the additional pre-recovery verification requirements when the intended recipient is known prior to organ recovery be removed from the proposal. Safeguards are built into current policy and the proposal such as deceased donors and candidates being blood typed twice and a requirement that two individuals make an independent report of the blood type in UNet. Matching is performed based on blood type results (and other factors) by a highly sophisticated computer system. Confirming the intended recipient prior to organ recovery isn't necessary and the proposed source to use when performing the verification is the OPTN computer system. The OPTN computer system is not a source document. Committee Response: Seven of the eleven regions approved this proposal. This proposal, however, was widely debated. The ASTS, ASHI, and American Nephrology Nurses Association support the proposal. AST opposes the proposal. AOPO commented that they appreciate the work but had several concerns they would like addressed. The OPO, Transplant Administrators, Membership and Professional Standards, Patient Affairs, Pediatric, Thoracic, Living Donor, and VCA Committees reviewed this proposal. The Committees were generally supportive although several committees did have suggestions or substantive comments that they wanted to be addressed. Identified concerns and requests and subsequent OSC responses are summarized below and organized by proposal goal. 1. Concerns about documentation. Confusion or misunderstanding over acceptable verification information sources. Concerns about site survey requirements. The OSC will provide education about acceptable sources. A verification is a confirmation of information. Because two people are required independently to enter blood type in UNet for both donors and candidates, the OPTN computer system is allowed to be the verification source in some cases. While some people disagreed with that philosophy and had concerns they could not trust the data, the OSC believes if it is strong enough to be used for the match run then this data can be used in some verification areas. The final pre-transplant verification does require that source documents be used. 2. Concerns over OPO requirements to perform verification at recovery Several commenters stated that they could not verify any recipient information because they do not have access to source documents. It is acknowledged that the OPO will not have recipient source documents. The OPTN computer system is named as an acceptable source. This allows the OPO to use DonorNet and the match run to verify this information. A verification is a confirmation of information and does not always require source documents. When source documents are required, the table of acceptable sources will be specific. It is acknowledged that the intended recipient might change. The information verified is what is known at the time of recovery. The proposal places the responsibility of conducting a verification at recovery with the OPO in order to be congruent with CMS. The CMS rule, §486.344 Condition: Evaluation and management of potential donors and organ placement and recovery, includes the following: (d) Standard: Collaboration with transplant programs. (1) The OPO must establish protocols in collaboration with transplant programs that define the roles and responsibilities of the OPO and the transplant program for all activities associated with the evaluation and management of potential donors, organ recovery, and organ placement, including donation after cardiac death, if the OPO has implemented a protocol for donation after cardiac death. (2) The protocol must ensure that: (i) The OPO is responsible for two separate determinations of the donor's blood type; (ii) If the identify of the intended beneficiary is known, the OPO has a procedure to ensure that prior to organ recovery, an individual from the OPO's staff compares the blood type of the donor with the blood type of the intended beneficiary, and the accuracy of the comparison is verified by a different individual; (iii) Documentation of the donor's blood type accompanies the organ to the hospital where the transplant will take place. (3) The established protocols must be reviewed regularly with the transplant programs to incorporate practices that have been shown to maximize organ donation and transplantation. (e) Documentation of beneficiary information. If the intended beneficiary has been identified prior to recovery of an organ for transplantation, the OPO must have written documentation from the OPTN showing, at a minimum, the intended organ beneficiary's ranking in relation to other suitable candidates and the recipient's OPTN identification number and blood type. This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: Pending OPTN/UNOS Executive Committee meeting, likely 2nd quarter 2016 Proposal to Modify the Sterile Internal Vessels Label This proposal seeks to modify the requirements for the sterile internal vessels label. The amount of information required on this label will be reduced. Currently all infectious disease results are required by policy to be handwritten on a “2 x 4” or “2 x 5” label in a sterile field. This process is difficult for OPOs to complete and prone to transcription errors. Infectious disease results on this label will be reduced to whether the donor is positive for Human Immunodeficiency Virus (HIV), Hepatitis B Virus (HBV), or Hepatitis C Virus (HCV) and whether the donor is at increased risk in accordance with US Public Health Service Guidelines for HIV, HBV, or HCV. Requirements for the hangtag poly-plastic internal label attached to the outermost layer of the triple sterile barrier will not change and all infectious disease results still must be completed on this label. Region 1 Vote: 12 yes, 0 no, 0 abstentions Comments: The region requested that the committee delineate the Hepatitis B results on the vessel label. Otherwise OPO coordinators may mark the HIV HBV or HCV question as “yes” when the donor is positive for Hepatitis B surface antibody. The region would like for the committee to consider adding a field for the match run ID so that the transplant center can easily find information in DonorNet. Committee Response: The OSC specifically asked for feedback on whether the positive indication for HBV should be for any positive HBV testing result or solely for HBsAg positive results as storage of these vessels is prohibited by policy. The majority of commenters, including the AST and three OPTN Committees, did want information about the different types of HBV results and requested that the label distinguish between different types of HBV test results. This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: September 1, 2015 Liver and Intestine Committee Proposed Membership and Personnel Requirements for Intestine Transplant Programs The proposed bylaw will define a designated intestine transplant program and establish minimum qualifications for primary intestine transplant surgeons and physicians. The proposal includes a full approval pathway and a conditional approval pathway to obtain the requisite experience to serve as the primary surgeon or primary physician. The intent is to set minimum standards where none currently exists without compromising quality or restricting new program formation. Region 1 Vote: 10 yes, 0 no, 1 abstention Comments: The region commented that the proposal strikes a balance between access and programs having some experience. It was also noted that intestine programs listed on the OPTN website is not up to date as many of the programs perform very few if any intestine transplants and this effort will establish an accurate list for patients to access. The region does have concerns about the 4 month application period. Programs may need additional time. Another concern is regarding the transition plan. Programs that will no longer perform intestine transplants will need to transfer candidates to other programs. During this transition period programs will be pending approval. How will an intestine program that is closing know where to transfer its candidates if programs have not yet been approved? Committee Response: This proposal lacks a detailed plan for application, transition and implementation. The plan for application, transition and implementation was established in collaboration with the UNOS Membership and Quality Department. Expected Implementation Plan: These Bylaws will be implemented pending approval of the new membership application for intestinal transplant programs by the Office of Management and Budget (OMB), programming and notice to members. All transplant hospitals with intestine programs with a current status of “Active, Approval Not Required” will receive an OPTN intestine transplant program application, along with a deadline for submission of the application. The application will be structured similarly to other current transplant program application forms. Transplant hospitals that receive this packet will be asked to complete all requisite information to apply for an intestine transplant program and submit the application within 120 days. Transplant hospitals that receive this application but do not intend to apply for an intestine transplant program will be asked to document this in writing and submit that documentation to UNOS. Transplant hospitals that do not receive an application but wish to apply for an intestine transplant program should contact the UNOS Membership Analyst for their region to obtain an application and the necessary instructions once the application period is announced. The proposed Bylaws will be slated for implementation following the 120-day application submission period. Every application received during the submission period will be acted on prior to implementation. Applications received after the deadline will be processed in the order they are received. Processing of applications received after the deadline cannot be guaranteed prior to the implementation date. Members will be alerted of the status of applications before the implementation date. Upon implementation of these proposed Bylaws, any transplant hospital without an approved intestine transplant program that has intestine or liver-intestine candidates on its waiting list must follow the patient notice and transition plan requirements described in OPTN Bylaws Appendix K (Transplant Program Inactivity, Withdrawal, and Termination). This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: Pending implementation and notice to members Pediatric Transplantation Committee Proposal to Establish Pediatric Training and Experience Requirements in the Bylaws Pediatric transplantation is a subspecialty within the field of transplantation. In the current OPTN Bylaws, the primary surgeon and primary physician are not required to have pediatric training or experience in order to serve as key personnel at programs that perform pediatric transplants. The Bylaws’ silence on pediatric program requirements means that there is not a universal standard of quality in pediatric care, which, in the most rare and serious of circumstances, could pose a risk to patient safety. In 2012, the Board of Directors included developing separate program requirements for pediatric programs as a key initiative under Goal 4: Promote Patient Safety of the OPTN/UNOS Strategic Plan and charged the Pediatric Transplantation Committee with developing Bylaws that fulfill this key initiative. The Committee proposes that a designated transplant program must have an approved pediatric component in order to perform transplants in patients less than 18 years old. To be approved for a pediatric component, a program must identify a qualified primary pediatric surgeon and a qualified primary pediatric physician to serve as key personnel. Region 1 Vote: 6 yes, 5 no, 2 abstentions Comments: The region generally supports the concept of the OPTN establishing pediatric program requirements. Below are comments made by those who opposed the proposal as written: The statement that low volume centers have worse outcomes than high volume centers is not backed up with data. It was noted during that meeting that this statement was generated by a statistically valid analysis of the SRTR data. The committee should reexamine adding an exception clause for a very sick patient. Looking at volume alone is not enough survival rates need to be part of the proposal. However UNOS has never used this as a standard for program approval. If used no new programs would ever be approved. Some concern regarding the number of transplants being proposed specifically for liver and kidney programs but it was noted that conditional approval is an option. The KM curves imply that surgical expertise is not the issue rather that medical care after one year is an issue. Committee Response: The Committee received support for this proposal from pediatric specialists, including organizations such as the American Society of Nephrology (ASN), the American Society of Pediatric Nephrology (ASPN), the North American Pediatric Renal Trial and Collaborative Studies, the Studies of Pediatric Liver Transplantation (SPLIT), as well as parents and family members of pediatric transplant patients. Transplant professionals supportive of the proposal voiced appreciation for defining the widely-accepted subspecialty of pediatrics in the Bylaws, as well as for establishing a standard of quality and safety for all pediatric patients. Parents expressed an expectation that these quality and safety standards exist, as well as a desire for all children to receive care from highly-qualified individuals who understand their unique needs. However, despite the Committee’s efforts to build consensus for proposed requirements, many recurrent themes emerged from public comment. These include that the proposal: Lacks evidence of a patient safety concern Cannot define a pediatric patient as less than 18 years old Lacks evidence to support the proposed caseload requirements Limits access to transplantation for pediatric patients Needs to stratify caseload requirements by age, weight, and other clinical factors. The proposal lacks evidence to support the proposed caseload requirements. Many have asked the Committee to produce evidence to support the proposed case volume requirements for the primary pediatric surgeon. As with all OPTN membership requirements involving case volume, the proposed case volume requirements were developed through clinical consensus. None of the OPTN membership requirements, alone, are predictive of good program outcomes. Many factors contribute to the success of a program. However, qualified key personnel are important contributors to a program’s success, and case volume is the most basic way a surgeon demonstrates requisite experience. The purpose of these requirements is to establish criteria for membership; therefore, the Committee does not have to demonstrate improved outcomes associated with these requirements. However, in an effort to build consensus, the Committee investigated outcomes data. A descriptive analysis of OPTN data showed significantly better unadjusted Kaplan-Meier graft and patient survival for pediatric transplants performed at high versus low volume kidney, liver, and heart programs from 1995-2010 (Exhibits B-D). High volume programs were determined using the proposed case volume requirements for each organ, i.e., at least 12 kidney transplants, 18 liver transplants, 8 heart transplants, and 4 lung transplants. While highvolume lung transplant programs also experienced better patient survival outcomes, the difference was not statistically significant (Exhibit E). Additionally, adjusted analyses that were performed independently by UNOS showed that as a group, centers performing <18 pediatric liver transplants during 2000-2010 had an increased risk of graft loss and death within 5 years (i.e., worse outcomes) as compared to centers performing 18+ pediatric liver transplants during that period; and centers that performed <12 pediatric kidney transplants during 2000-2010 had an increased risk of graft loss and death within 5 years (i.e., worse outcomes) as compared to centers that performed 12+ pediatric kidney transplants during that period (Exhibit F-G). The proposal limits access to transplantation for pediatric patients. In response to feedback from the Regions, the Committee made major comprises in the development of these proposed Bylaws in the interest of access to transplantation for pediatric patients. The resulting proposal better balances the competing interests of quality of care, including patient safety, and access to transplantation for pediatric candidates. In fact, from January 1, 2005 through July 31, 2014, 97.7% of pediatric transplants were performed at centers that would have met the proposed pediatric volume criteria. Again, because of the limitations of OPTN data, center volume is being used as a proxy for primary surgeon volume. A low volume center could still be approved for a pediatric component so long as a surgeon that has performed the required number of pediatric surgeries over the history of his or her career can serve as key personnel. Programs may also take advantage of a 24-month conditional pathway to establish a new pediatric component or accommodate a change in key personnel. The Committee continues to receive requests for an exception that would allow programs without a pediatric component to perform a pediatric transplant in an emergency, such as acute fulminant liver failure. The Committee has thoroughly considered and decided against proposing such an exception, which would represent a departure from the current standard that OPTN members must fully meet program and program component requirements in order to perform transplants. In these exceedingly rare instances, patients can be safely transported to qualified pediatric component program. The proposal needs to stratify caseload requirements by age, weight, and other clinical factors. At the Regional Meetings in the fall of 2013, the Committee presented initial requirements that were stratified by age, weight, and other relevant clinical factors in an effort to build consensus prior to public comment. Among the initial requirements, the primary pediatric kidney surgeon must have performed 6 transplants in patients weighing 20 kilograms or less at time of transplant, and the primary pediatric liver surgeon must have performed 9 transplants in patients less than 12 years old and 5 technical variants, including split, reduced, or living donor liver transplants. This experience had to be achieved over a recent five year period. As mentioned above, the Committee received overwhelming feedback to modify the requirements to preserve access to transplantation for pediatric patients. In response, the Committee eliminated stratifications from the pediatric caseload requirements and proposed that the requisite surgeries could be performed over an entire career, so long as the surgeon demonstrates currency of experience as currently defined in the Bylaws. Informed by the development process, the Committee knows it cannot achieve consensus for stratified caseload requirements and recognizes its responsibility to balance quality of care with access to transplantation for pediatric patients. A majority of the directors present voted in favor of this proposal, however the Bylaws require that a majority of the entire Board must vote to approve changes to the bylaws. Therefore, these proposed modifications to the Bylaws were not approved. The Board directed that the interested parties including the Pediatric Committee and representatives of the professional societies including the ASTS collaborate to develop an acceptable proposal that could be distributed for public comment in the fall 2015 cycle. Organ Procurement Organization Committee Proposal to Address the Requirements Outlined in the HIV Organ Policy Equity Act Current federal rules and OPTN policy prohibit the recovery and transplantation of organs from deceased donors infected with the human immunodeficiency virus (HIV). The HIV Organ Policy Equity Act, enacted on November 21, 2013, will allow for the development and publication of criteria for the conduct of research relating to transplantation of organs from donors infected with HIV into individuals who are infected with HIV before receiving such organ. The goal of this proposal is to continue to amend OPTN policies to allow members to participate in the research study in accordance with upcoming changes to the Final Rule and criteria developed by the Secretary of Health and Human Services (HHS). Region 1 Vote: 11 yes, 0 no, 0 abstentions This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: Pending programming and notice to members Ad Hoc Disease Transmission Advisory Committee Proposal to Require Re-Execution of the Match Run when a Deceased Donor’s Infectious Disease Results Impact Potential Recipients based upon Screening Preferences The purpose of Policy 2.9 (Required Deceased Donor Infectious Disease Testing) is to determine whether deceased organ donors have evidence of infection with a number of potentially transmissible pathogens. For some of these specific pathogens, organ transplant candidates may choose not to receive offers from positive donors. In this case, these candidates do not appear on a match run. Current policy does not require the host OPO to re-execute the match run if new results become available after execution of the initial match run. This updated donor information could screen certain candidates from receiving organ offers. Review of OPTN data indicates that a large number of organ allocations take place using match runs executed prior to receipt of all test results. This presents a potential patient safety concern, as organs could unintentionally be allocated to a candidate who is not willing to accept offers from organs who are positive for a specific infectious disease. This could result in unintended donorderived disease transmission. Better defining in policy the processes that should be followed when new results are learned after the initial match run will reduce the opportunity for error and enhance patient safety. Region 1 Vote: 10 yes, 1 no, 0 abstentions Comments: One member made the comment that the OPO should always rerun the match when positive infectious disease results become available even with a provisional yes. This ensures that only candidates willing to accept CMV HBV and HCV positive will appear on a match for a donor with a positive test result. Committee Response: Public comment generated little concern from individuals, groups, or committees and received support from 10 of the 11 regions in support. The American Society of Transplantation submitted substantial comments. Overall comments were grouped into four themes: This proposal does not go far enough- all match runs should be re-executed when this information is received. The Committee was originally supportive of a requirement to always require re-execution of the match run in these circumstances. Upon discussion in the larger joint subcommittee, including representation from both the Operations & Safety and OPO Committees, the Committee grew to appreciate the transplant surgeon perspective of honoring the primary potential transplant recipient’s acceptance when seen as an appropriate organ by the surgeon and upon obtaining informed consent of the potential recipient. While in most cases, the joint subcommittee believes that this provisionally accepted organ will be declined based upon this new information, the group felt strongly that it was an appropriate compromise to make in light of the logistics of sometimes having a potential recipient admitted, consented, and cleared for transplant. Several commenters noted that OPOs should put more effort on completing tests before executing a match run, while others raised concerns that OPO should not wait for all information to generate a match run- as this could impact donor stability and organ quality. For all of these reasons, the Committee is confident that this compromise approach outlined in the three separate pathways is a reasonable way to enhance patient safety while not removing the ability for the potential recipient’s care team to exercise medical judgment as appropriate. This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: Pending programming and notice to membership Vascularized Composite Allograft Committee Membership Requirements for Vascularized Composite Allograft Transplant Vascularized Composite Allografts (VCAs) were included in the OPTN Final Rule (42 CFR part 121) as covered human organs effective July 3, 2014. In response to this change, the OPTN Board of Directors approved minimal VCA membership requirements that will expire on September 1, 2015. Under the current rules, there are no specific membership requirements with regard to VCA transplant experience for the primary physician and surgeon at a VCA program. The VCA Committee is proposing minimal certification, training, and experience for individuals serving as VCA primary physicians and surgeons. If approved, these new requirements will replace those requirements that will expire in September 2015. Region 1 Vote: 9 yes, 0 no, 1 abstention This proposal was approved during the June 2015 OPTN/UNOS Board of Directors meeting. Effective Date: Pending programming and notice to members