MEETING SUMMARY Region 6 Meeting Portland, Oregon May 16, 2014 Public Comment Items Proposed during fall 2013 Following is a summary of the region’s comments on each proposal out for public comment during the spring of 2014, the sponsoring committee’s response to regional comments, if appropriate, and the OPTN/UNOS Board of Directors action on each proposal. Proposal to Require the Collection of Serum Lipase for Pancreas Donors (Pancreas Transplantation Committee) This document proposes to make serum lipase a required field in Policy 2.8.E Required Information for Deceased Pancreas Donors, as well as required in DonorNet®, in order to make electronic pancreas offers. Currently, serum lipase is a listed field in DonorNet ®, but is not required in order to make electronic pancreas offers. Serum lipase level(s) in deceased donors are reliable indicators of pancreas function and quality. As such, the serum lipase values assist in making an informed clinical decisions regarding electronic pancreas offers. The proposal also proposes to create a new field in DonorNet® where OPOs will report the upper limit of normal (i.e. maximum normal value or highest reference value) of the laboratory’s normal serum lipase reference range. The reason for programming this new field is because laboratories’ measurement ranges vary for serum lipase. As a result, a serum lipase value may have two different meanings at two different laboratories. This results in varying “normal” serum lipase values across the country. This new field will provide a reference point regarding the serum lipase value to the physician making the decision whether to accept the pancreas. Region 6 Vote: 35 yes, 4 no, 0 abstentions This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: upon implementation and notice to members Proposal to Require the Reporting of Aborted Living Donor Organ Recovery Procedures (Living Donor Committee) Promoting patient safety is a critical component of the OPTN’s mission. The OPTN seeks to protect the safety of transplant candidates, recipients, and living donors, but living donors are unique in that they put themselves at risk without any potential benefit to their own health. Due to a variety of reasons, including last minute recipient or donor health problems and unforeseen donor anatomy issues, living donor organ recovery procedures occasionally need to be aborted after anesthesia has been administered, but before the recovery of the organ. Monitoring the safety of these prospective donors is an important part of the OPTN’s goal of promoting living donor safety. The OPTN relies on the UNetSM Improving Patient Safety Portal for notification of patient safety concerns and living donor adverse events. Under this proposal, an aborted living donor organ recovery procedure would become a new category of living donor adverse event that recovery hospitals would need to report through the UNetSM Improving Patient Safety Portal. Additionally, the proposal would clarify current living donor adverse event reporting requirements by eliminating some redundant sections of policy. Region 6 Vote: 50 yes, 0 no, 0 abstentions This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: upon implementation and notice to members Proposal to Clarify Data Submission and Documentation Requirements (Membership and Professional Standards Committee (Membership and Professional Standards Committee) Policy 18.1 (Data Submission Requirements) requires members to submit data to the OPTN through the use of standardized forms. However, Policy 18.1 does not explicitly state that the data submissions must be accurate or that members must be able to provide documentation to verify the accuracy of their data submissions. The MPSC historically has agreed that the need for accurate data is implied within Policy 18.1, as is the member’s obligation to provide documentation to verify the data’s accuracy. This proposal’s goal is to amend Policy 18.1 to explicitly state that the data must be accurate and that members must provide documentation to support their data. Region 6 Vote: 50 yes, 0 no, 0 abstentions This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: February 1, 201 Proposed ABO Subtyping Consistency Policy Modifications (Operations and Safety Committee) This proposal seeks to make all ABO subtype references consistent throughout OPTN policies. Current references use different terms, such as A2 and non-A1, which are intended to mean the same thing but may be confusing. The more technically accurate description uses the “non” preface as routine testing only detects the presence or absence of A1 and other rare subtypes other than A2 do exist. In 2011, the OPTN published guidance on this issue. The proposed changes will align references with this guidance using the terms blood type A, non-A1 and blood type AB, non-A1B. Region 6 Vote: 50 yes, 0 no, 0 abstentions This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: May 1, 2015 Proposal to Allow Non-substantive Changes to the OPTN Policies and Bylaws (Policy Oversight Committee) On occasion, clerical errors are identified in the Policies and Bylaws. These clerical errors are noncontroversial things like obvious misspellings and mis-numbering of lists. There is nothing in the Bylaws or Policies that allow staff to make these non-substantive changes. This proposal would allow staff to make non-substantive changes without needing approval by the Executive Committee or Board of Directors. The Executive Committee would review these changes retrospectively. Region 6 Vote: 50 yes, 0 no, 0 abstentions This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: February 1, 2015 Discussion Agenda Ad Hoc Disease Transmission Advisory Committee Proposal to Align OPTN Policies with the 2013 PHS Guideline for Reducing Transmission of Human Immunodeficiency Virus (HIV), Hepatitis B Virus (HBV), and Hepatitis C Virus (HCV) Through Solid Organ Transplantation. The Final Rule §121.4 (OPTN policies: Secretarial review and appeals.) notes that the OPTN Board of Directors is responsible for developing policies that are consistent with recommendations of the Centers for Disease Control and Prevention (CDC) to test potential organ donors and following transplant recipients to prevent the spread of infectious disease. The June 19, 2013, release of the PHS Guideline for Reducing Human Immunodeficiency Virus (HIV), Hepatitis B Virus (HBV), and Hepatitis C Virus (HCV) Through Organ Transplantation led to a systematic review of related OPTN policies. This proposal seeks to modify some existing policy language and also create new policies to reflect recommendations outlined in this updated PHS document. Region 6 Vote: 48 yes, 0 no, 0 abstentions Region 6 Comments: There should be a check box added so that when a program is listing a candidate, they can indicate whether or not they would accept an organ from an HCV Nat + donor. Also, Living Donor recovery centers should not be required to screen for all transmissible diseases within 28 days prior to organ recovery if the living donor is not high risk. The only requirement for non-high risk donors should be HCV Nat. Committee Response: The Committee appreciates this feedback. Programming is included in this proposal to screen recipients not willing to receive NAT positive organs for transplant. This will be in addition to screening already in place for serology positive organs. The Committee appreciates concerns related to the decreased time period for final infectious disease screening for living donors. Unfortunately, there have been window period infections in living donors that were transmitted to recipients. For this reason, the Committee remains supportive of the 28 day window proposed in the PHS Guideline. While potentially inconvenient for the living donor and the organ recovery hospital, this will prevent scenarios where a donor is tested early in the evaluation process and then may unknowingly become infected between screening and donation. Reducing the opportunity for window period infection will enhance donor and recipient safety. This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: February 1, 2015 except NAT requirements NAT requirements will be implemented upon programming and notice to members Transplant Coordinator Committee Proposal to Notify Patients Having an Extended Inactive Status The goal of this proposal is to promote effective and safe care for organ candidates by increasing awareness of their inactive waiting list status. Published literature suggest that the longer candidates wait for an organ while in an inactive status, the less likely they are to receive a transplant. In addition, the Committee is concerned that candidates are not consistently informed of their status nor do they understand what it means to have an inactive status. Region 6 Vote: 4 yes, 53 no, 0 abstentions Comments: Several members were concerned that the data did not support this being a wide-spread problem and agreed that this issue should be addressed with individual centers and not put into national policy. This would be burdensome for the centers and is already reported to the dialysis centers through the nephrologists. If implemented, an annual letter would be more reasonable than a letter at 90 days and then annually. Based on public comment, the committee decided not to submit the proposal to the Board in November. Instead, they will explore ways to inform the transplant community of effective patient notification practices. The committee will also review the data and revisit the proposal after KAS has been impleneted for six months and one year to see if there is any effect on the inactive waiting list. Histocompatibility Committee Expanding Candidate and Deceased Donor HLA Typing Requirements to Provide Greater Consistency Across Organ Types The proposed changes make the HLA typing methods and list of HLA loci to be reported consistent for deceased donors across all organ types. The required methods and list of HLA loci to be reported will apply both when OPTN policy requires HLA typing be performed and reported on the deceased donor prior to allocation (i.e. for kidney, kidney-pancreas, and pancreas allocation) and in instances where HLA typing is required only if requested by the candidate’s transplant program (i.e. for heart, heart-lung, and lung allocation). The proposal includes new requirements for reporting HLA-DQA and HLA–DPB for deceased donors. The time period for reporting deceased donor HLA typing remains different by organ type to meet varying clinical requirements for timing of transplants. The proposal newly requires HLA typing to be performed and reported for deceased liver donors if requested by a transplant program and makes HLA typing requirements for deceased pancreas islet donors and candidates consistent with those for deceased pancreas donors and candidates. Region 6 Vote: 55 yes, 0 no, 1 abstention Comments: The members agreed that the unacceptable antigen fields should be added in UNet, so that these organ offers are automatically screened off from candidates with antibodies to these types. This is needed to do a virtual crossmatch. Committee Response: The Committee met in person on August 11-12, 2014 to review public comments received on this proposal. During review of the public comments, members agreed that HLA-DPA should be included in the list of loci, however, this change was considered outside the scope of this proposal and would need to be addressed through the development of a new project. As a result of favorable public comment, the Committee voted unanimously to recommend approval of the proposal, without changes, to the Board of Directors. In response to specific public comment feedback on whether to include HLA-DQA and HLA-DPB fields in DonorNet® only or to DonorNet® and WaitlistSM, the Committee unanimously agreed with the majority of commenters that the proposal should be programmed to include HLA-DQA and HLA-DPB fields in DonorNet® and HLA-DQA and HLA-DPB fields in WaitlistSM as unacceptable antigens. This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: Upon programming and notice to members Living Donor Committee Proposal to Modify Existing or Establish New Requirements for the Informed Consent of all Living Donors This proposal would modify existing policy and establish new policy requirements for the informed consent of all living donors. This proposal is in response to a directive from the Health Resources and Services Administration (HRSA) to develop such policy, and is based on recommendations from a Joint Societies Steering Committee composed of representatives of the American Society of Transplantation (AST); the American Society of Transplant Surgeons (ASTS) and the North American Transplant Coordinators Organization (NATCO) to the Living Donor Committee. Policy to standardize the informed consent of living kidney donors has already been established. This proposal would modify some elements of exiting policy for the informed consent of living kidney donors and establish new requirements for all other categories of living organ donors. Region 6 Vote: 48 yes, 0 no, 0 abstentions This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: Febraury 1, 2015 Proposal to Modify Existing or Establish New Requirements for the Psychosocial and Medical Evaluation of all Living Donors This proposal would modify existing policy and establish new policy requirements for the psychosocial and medical evaluation of all types of living donors. This proposal is in response to a directive from the Health Resources and Services Administration (HRSA) to develop such policy, and is based on recommendations from a Joint Societies Steering Committee composed of representatives of the American Society of Transplantation (AST); the American Society of Transplant Surgeons (ASTS) and the North American Transplant Coordinators Organization (NATCO) to the Living Donor Committee. Policy to standardize the medical evaluation of living kidney donors has already been established. This proposal would modify some elements of existing policy for the psychosocial and medical evaluation of living kidney donors and establish new requirements for the psychosocial and medical evaluation for all living organ donors. Region 6 Vote: 46 yes, 2 no, 0 abstentions Comments: There was some discussion about the need for HepBsAg testing for liver donors since this is really not a problem for the recipient. Committee Response: The Committee appreciates this response. All testing or screening requirements in the proposal are based on recommendations from a Joint Societies Work Group and the Disease Transmission and Advisory Committee. This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: February 1, 2015 Kidney Transplantation Committee Kidney Paired Donation (KPD) Histocompatibility Testing Policies This proposal includes requirements for histocompatibility testing on donors and recipients in the OPTN KPD Program. It includes required methods for HLA typing, antibody screenings, and crossmatching; a list of HLA types that must be reported for donors and candidates; and processes that must be followed for identifying unacceptable antigens and in the event of unacceptable positive crossmatches. Region 6 Vote: 51 yes, 0 no, 0 abstentions Comments: The region requested clarification of policy section 13.5.A, 2. to indicate that if a candidate had antibody to on one HLA type, for example HLA C, they would only need to be typed for HLA C not DR, DPB etc. The group did not come to consensus about screening all candidates every 90 days. The transplant programs thought this was not necessary and the Histo labs thought it was a good idea because they would not be aware of a sensitizing event. There was no comment on having the candidate inactivated automatically by UNOS versus having the center inactivate. Committee Response: The Committee amended the proposal to make clear that the candidate’s transplant program is only required to report the corresponding candidate HLA type if the candidate reports unacceptable antigen. The Committee appreciates your question and attention to detail. This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: Upon programming and notice to members Liver and Intestinal Transplantation Committee Proposal to Cap the HCC Exception Score at 34 Candidates with a MELD/PELD score exception for HCC receive high priority on the liver waiting list, especially as their exception scores may increase automatically every three months. Increasingly, there are candidates with multiple HCC exception extensions who are now receiving regional offers under the “Share 35 Regional” policy implemented in June 2013. These candidates are likely to have a much lower risk of disease progression or dropout (i.e., removal from the waiting list for death or being too sick) than candidates with calculated MELD/PELD scores of 35 and higher. This proposal would cap the HCC exception score at 34, in effect giving candidates with calculated MELD/PELD scores of 35 and higher a better opportunity to receive regional offers under the new policy. Region 6 Vote: 58 yes, 0 no, 0 abstentions Comments: There was general agreement that the MELD should be capped, but several of the members thought that 34 was probably too high and asked that the committee look at data if the cap was lower. Committee Response: While the Subcommittee acknowledged that some members of the community have voiced a concern that the cap should be lower than 34, the intent of the proposal was to exclude patients with HCC Exceptions and a lower rate of drop-off from the regional sharing under Share 35. Capping at any other particular MELD was not likely to be effective due to current regional variation. This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: Upon programming and notice to members Proposal to Delay HCC Exception Score Assignment Candidates with a MELD/PELD score exception for HCC receive high priority on the liver waiting list, especially as their exception scores may increase automatically every three months. These candidates have significantly lower dropout rates (i.e., removal from the waiting list for death or for reasons related to the HCC) than non-HCC candidates, with the exception of those areas of the country with lengthy waiting times. The proposed solution to address the disparities in drop-out rates between patients with HCC exceptions and those without is to delay the score assignment by 6months. Simulation modeling has shown that this would equalize the transplant and drop-out rates for those with and without HCC exceptions. In areas of the country with shorter waiting times to transplant, the delay will also allow a window of time for centers to observe candidates with rapidly growing tumors who may have very poor outcomes with a transplant. At least one study indicates that candidates with HCC exceptions in regions with shorter waiting times to transplant, where this “biologic test” is not met due to rapid transplantation, have worse post-transplant outcomes. Region 6 Vote: 50 yes, 0 no, 0 abstentions Comments: There were questions about the dropout rate for HCC exceptions who meet criteria versus those who do not and if this varied greatly by region. There was also concern that these changes to policy would have an unknown effect on the goals of the re-districting. Committee Response: Some commented that this proposal would not alleviate the current geographic disparity. This proposal is intended to reduce the disparity in waiting list drop-out rates (removals for death/”too sick”/other removals due to HCC) between HCC and non-HCC candidates, not to reduce the national geographic disparity. The Committee is currently pursuing other projects to address the national geographic disparity. Likewise, this policy proposal was not intended to address OPO performance. This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: Upon programming and notice to members Proposed Membership and Personnel Requirements for Intestine Transplant Programs (in collaboration with the Membership and Professional Standards Committee) 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 perform primary surgical and medical care. The intent is to set minimum standards where none currently exist without compromising quality or restricting new program formation. Region 6 Vote: 47 yes, 0 no, 0 abstentions Comments: The region supported this proposal unanimously but agreed that the training and experience numbers should be higher. The pediatric members understood that the committee will always get pushback that the numbers are either too high or too low and that this is probably as good as we can get. This proposal has been modified and will go out for public comment in January 2015 Membership and Professional Standards Committee Proposal to Allow a MPSC Recommendation to the Board of Directors for Approval Consideration of a Non Qualifying Transplant Program Applicant Located in a Prescribed Geographically Isolated Area The proposed bylaw language makes available a mechanism by which the MPSC may make a recommendation to the Board, and the Board may consider and approve the designation of transplant programs who currently cannot meet key personnel qualifying criteria because the applicant is located in a geographically isolated area. Currently, if an applicant cannot meet the program requirements, then the application is closed by the MPSC as rejected, leaving the applicant to appeal to the HHS Secretary for any further approval consideration of the closed application. Region 6 Vote: 52 yes, 0 no, 0 absentions This proposal was approved during the November 2014 OPTN/UNOS Board of Directors meeting. Effective Date: February 1, 2015 Operations and Safety Committee Proposed ABO Blood Type Determination, Reporting, and Verification Policy Modifications Member feedback has long noted the complex phrasing and requirements related to ABO blood type determination and verification. These requirements are a fundamental step in safe and successful organ transplantation. The Committee is proposing clarifications and improvements to these requirements. These recommendations are based, in part, from a Failure Modes and Effects Analysis (FMEA) conducted to proactively identify areas of risk related to ABO processes in deceased donation. This policy proposal is only one facet in the Committee’s approach to improving ABO blood type determination and verification. Other strategies to minimize identified risks and maximize human factors engineering include member education and competency training, programming changes to UNet℠, and collaboration with the Electronic Tracking and Transport (ETT) project to improve technological capabilities. This policy proposal contains the following features: Clarified existing requirements related to commonly asked questions Strengthened safety components to ensure the correct organ is transplanted into the correct recipient and that the match is ABO compatible or intended incompatible Modified the timing of deceased donor blood type determinations and reports prior to executing the match run with an exception for accelerated donor cases Modified the timing and scope of verifications for deceased and living donor organ recoveries Clarified specific verification elements and sources Better aligned OPTN and Centers for Medicare and Medicaid Services (CMS) requirements Added conditional requirements to check in organs upon arrival and to perform a pretransplant verification Added a requirement for qualified health care professionals to perform ABO reporting and verification functions Made deceased and living donor standards more consistent Region 6 Vote: 0 yes, 38 no, 0 abstentions Comments: In many cases OPOs do not have and cannot verify recipient information. Some of the proposal is reasonable, but there is so much wrapped up into this one proposal there is no way to pull out the good sections from the sections that are inconsistent with practice. Committee Response: The Committee has received multiple comments concerning the ability to perform a verification at deceased donor organ recovery when the intended recipient is not known. The Committee has proposed post-public comment changes in response to these comments. The Committee acknowledges that the proposal contains proposed changes to multiple sections. The Committee is appreciative that the region acknowledges that the proposal contains good sections. This policy proposal was tabled during the November 2014 OPTN/UNOS Board of Directors meeting and will go back out for pubic comment in January 2015. Thoracic Transplantation Committee Proposal to Continue the Adolescent Classification Exception for Pediatric Lung Candidates On June 10, 2013, the OPTN/UNOS Executive Committee approved a temporary policy permitting lung candidates less than 12 years old to request an exception from the Lung Review Board (LRB) to be classified as an adolescent candidate for the purposes of prioritization by lung allocation score (LAS) for lung offers from donors 12 years of age and older. Unless further action is taken by the Board of Directors, the “adolescent classification exception” will expire on July 1, 2014. Because the temporary policy permits young pediatric lung candidates who may be suitable for lung offers from larger donors to apply for an exception, the Thoracic Committee proposes removing the July 1, 2014, deadline from the policy making this a permanent policy change. The Thoracic Committee also proposes additional language to clarify the data reporting requirements for candidates with approved adolescent classification exceptions. Region 6 Vote: 33 yes, 0 no, 0 abstentions This proposal was approved during the June 2014 OPTN/UNOS Board of Directors meeting. Effective Date: July 1, 2014