Today, FAH submitted comments urging the Center for Medicare and Medicaid Innovation (CMMI) to delay and refine its proposed Increasing Organ Transplant Access (IOTA) Model, which would create a new mandatory payment model for 90 kidney transplant hospitals.
In addition to opposing the mandatory approach that would include half of all kidney transplant hospitals, the letter raised concerns that the IOTA Model, as proposed, is not ready for implementation – especially for the proposed start date of January 1, 2025. The letter details how the model would inappropriately incentivize exorbitant transplant program growth and how participating hospitals would find it very challenging to succeed under the current design.
FAH’s letter urges CMMI to push back implementation, work with stakeholders to address concerns related to downside risk and unachievable performance measures, develop program-specific quality measures for transplantation, and avoid any mandatory approaches in the future.
