On May 8, 2024, CMS issued a proposed rule for establishing the Increasing Organ Transplant Access Model (IOTA Model). As proposed, the IOTA Model would run for six years starting on January 1, 2025, in Donation Service Areas (DSAs) across approximately half the country. This IOTA Model intends to test if providing performance-based incentive payments to participating kidney transplant hospitals will improve access to kidney transplant procedures without compromising patient health outcomes.

Although the IOTA Model is experimental, participation will be mandatory for hospitals that:

1. performed at least eleven kidney transplants for patients 18 years of age or older annually over a designated three-year period; and
2. provide more than half of their annual kidney transplants to patients 18 years of age and older.

The IOTA Model’s proposed incentive structure would not only reward hospitals that achieve program goals but will also implement consequences for sub-par performance. The IOTA Model would evaluate each participating hospital with a score between zero points and one hundred points. CMS would award sixty out of one hundred points on the basis of the number of transplants each transplant hospital provides compared to a CMS-established benchmark. CMS would award another twenty points using a formula calculating how efficiently each transplant hospital converts “offered” kidneys into successful transplant procedures. CMS would award the final twenty points on a measure of post-transplant outcomes to confirm continuing quality of care. Transplant hospitals that receive a score of at least sixty points would receive “upside risk payments” from CMS as a reward. Hospitals that receive forty or fewer points would be subject to “downside risk payments” to CMS as a penalty. Transplant hospitals whose scores fall in between both categories would receive neither a payment nor a penalty.

CMS has not yet indicated which donor service areas (DSAs) would participate in the IOTA Model but has signaled that it will select DSAs at random. Stakeholders may submit comments to CMS regarding the proposed rule prior to July 16, 2024. The display copy of the proposed rule can be found here, and a fact sheet regarding the rule can be found here. The proposed rule is expected to be published in the Federal Register on May 17, 2024.