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October 20, 2022 11:23 AM

Letters: Senator’s criticism of U.S. organ donation system misguided

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    As a leader in the U.S. organ donation and transplant community with more than two decades of experience and a former member of the United Network of Organ Sharing (UNOS) Board and Liver Committee that undertook the initial development of liver allocation policy, I must take issue with Kansas Sen. Jerry Moran’s position in a recent op-ed (“Competition needed to address a flawed organ donation system,” Modern Healthcare, annual congressional policy supplement, Sept. 19).

    The changes made in organ allocation by UNOS were designed to address health, demographic and racial inequities and improve transplant outcomes and reduce waitlist deaths. These changes mirror the changes made in kidney, heart and lung allocation and were adopted after a decade-long policy development process that included extensive and multiple public comment opportunities. Further, they were approved by a board made up of representatives from transplant centers, organ procurement organizations (OPOs), transplant laboratories and patient support groups from across the nation.

    The liver allocation changes have been the subject of numerous lawsuits and appeals based on arguments similar to Sen. Moran’s, and each has been denied by the courts because the process followed was consistent with UNOS policy and the guiding federal law, the National Organ Transplant Act of 1984, and the Medicare Final Rule of 1998, which mandates organs be shared as broadly as clinically possible with the intent of equity of access for all Americans.

    Under the former organ allocation rules, patients living as few as 100 miles apart could experience vastly different wait times for livers–often a year or longer than patients in neighboring regions–even though livers can be transported and remain viable for six hour plus. The new liver allocation system has rectified this and other inequities and enabled significant increases in transplant rates for Per UNOS 18-month monitoring report on the liver allocation policy, “sicker/higher MELD patients (“Model End Stage Liver Disease” score, adopted by UNOS in 2002 to rank order patients by need), 133 fewer waitlist removals for deaths or too ill to transplant, and a 5.1% increase in liver transplants.”

    Nonetheless, Sen. Moran writes: “many of the organs donated in the Midwest are sent hundreds of miles away to coastal urban areas where people donate organs at a much lower rate.” But in fact, per UNOS data, no livers from Kansas donors have gone to patients in California, New York or New England this year. The reality is that the new allocation rules call for livers to be distributed first to patients at transplant centers within 500 nautical miles (nm) of the donor hospital, unless there are patients waiting who are extremely ill and a biological match, and then that radius is reduced to 150nm. Livers are only sent beyond the 500nm range when transplant centers within 500nm have declined the organ for all their patients. Neither of these distances would result in a liver being sent from the senator’s district to “hundreds of miles away to coastal urban areas,” which are between 750-1,500+ miles away from Kansas.

    The senator’s understanding of the rules is fundamentally incorrect, and his recommendation would result in the tragic deaths of too many Americans.

    Tom Mone
    Chief external affairs officer, 
    OneLegacy, the organ procurement organization serving the Greater Los Angeles, Southern California area

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