A new study has found that the upcoming Centers for Medicare & Medicaid Services (CMS) decertification actions for Organ Procurement Organizations (OPOs) may disproportionately impact racially and ethnically diverse communities, potentially exacerbating longstanding inequities in organ donation and transplantation. The article entitled “Centers for Medicare and Medicaid Services Performance Metrics and the Disproportionate Impact of Decertifying Organ Procurement Organizations on Minority Populations,” was authored by James R. Rodrigue, PhD of New England Donor Services and Harvard Medical School, as well as Sean Fitzpatrick, MPA and Brandon McKown, MBA of New England Donor Services.
According to the article and press release, CMS’s unadjusted performance measures fail to account for structural and social determinants – including historical mistrust, lower donor registration rates, and differential authorization patterns – that shape organ donation in diverse communities. Without making the necessary adjustment for these factors, the authors argue, OPOs serving multicultural populations may be inaccurately labeled as underperforming.
“A balanced policy framework that recognizes contextual complexity while upholding rigorous performance standards is essential to ensuring that reforms designed to improve the system do not, in turn, deepen the inequities they seek to overcome.”
OPOs projected for Tier 3 (automatic decertification) serve the highest proportions of non‑White residents, with 57 percent of their donation service areas made up of minority populations—compared with just 31.9 percent in Tier 1. Statistically, OPOs serving larger shares of Black, Hispanic, and other minority populations are significantly more likely to fall into lower CMS tiers and risk being decertified.