The AAMC submitted a July 12 comment letter (PDF) to the Centers for Medicare & Medicaid Services (CMS) on the new mandatory Increasing Organ Transplant Access (IOTA) Model. IOTA aims to increase access to kidney transplants, improve the quality of care for people seeking kidney transplants, reduce disparities among individuals undergoing the process to receive a kidney transplant, and increase the efficiency and capability of transplant hospitals. The CMS proposed to assess programs based on increases in the number of transplants performed compared to those completed over a three-year historical period and national trends.
In its comment letter, the AAMC recommended that the CMS:
- Delay the start of the IOTA Model due to the active Organ Procurement and Transplantation Network requests for proposals to reduce potential errors to attribution.
- Include additional measures to fully assess quality performance, such as the Hemoglobin A1c Poor Control (>9%) measure and the Advance Care Plan measure.
- Use a five-year fixed historical period for the baseline calculation to reflect a participant’s past performance more accurately in the achievement domain.
- Implement a waiver to expand the use of Medical Nutrition Therapy services to increase the number of patients who meet transplant criteria and can, subsequently, receive a transplant.
If finalized, the IOTA model would start Jan. 1, 2025, and end Dec. 31, 2030.