Just for fun, decided to try to drill down to nitty gritty re fed rules & regs re organ procurement & donation.
IIUC,
- following applies to med centers/hosps performing organ transplants & receiving Medicare or Medicaid funds.
- fed. standards (X052 Patient Selection; X053, Psychosocial Evaluation) had already been adopted by HHS,
- this memo announces 'Interpretive Guidelines' about written policies transplant centers must develop.
- w'in these ^guidelines, ea transplant center sets written policy for transplants performed there
- develops criteria for selecting transplant candidates.
- before putting patient on list, transplant centers are required (gen'ly) to make psychosocial evaluation.
Hoping some of
our medical professionals can offer correction or clarification, to my interp of what this applies to. Linked to this, w my bolding and underscoring:
http://www.cms.gov/Medicare/Provide...ulations/Transplant-Laws-and-Regulations.html
http://www.cms.gov/Medicare/Provide...oads/SurveyCertLetterSOMandSurveyProtocol.pdf
Letterhead = Dept. of Health & Human Services / CMS
Date: June 13, 2008
To: State Survey Agency Directors
From: Director / Survey & Certification Group
Subject: Advance Copy - Organ Transplant Program Interpretive Guidelines
[effective date 30 days after memo date]
Advance Copy - Subpart E Requirements for Specialty Hospitals
----------------------------------------------------------------------------------------------------------------
Attachment A:
Organ Transplant Surveys, Interpretive Guidelines
Transplant Center Process Requirements [starting on page#: digital=30; hard copy= 27]
X052
(a) Standard:
Patient Selection. Patient selection criteria must ensure fair and non-discriminatory distribution of organs.
Interpretive Guidelines
Review the transplant programs written transplant patient selection
criteria. The selection criteria (medical, psychosocial, financial, etc.) must clearly define the characteristics of the patients for whom the program will and will not provide transplant services. These criteria may
not exclude groups of individuals based on factors such as
race, ethnicity, religion, national origin, gender, or sexual orientation.
Please note, there are factors that some transplant programs
can and do use in their patient selection criteria including
age, ability to pay, ability to adhere to immunosuppression regimen, presence of an active infection, etc. Consideration of these types of factors is permissible.
Review the complete list of the transplants performed by the program within the last 3 years or June 28, 2007, whichever is most recent. The list should include, at a minimum: name, address, country of primary residence, resident alien or nonresident alien status, race, and gender. Compare the transplant programs patient selection criteria and the list of transplants performed for the last 3 years for any patterns that suggest the programs selection criteria are not being followed.
Include questions in the interview process of transplant program staff to verify that the transplant programs policy is being followed.
If patterns of discriminatory distribution of organs by the program are identified, contact the appropriate CMS Regional Office for further instruction. Such patterns may indicate that the national organ allocation (OPTN) policy is not being followed appropriately. Each organ allocation is reviewed by the OPTN. It is outside the scope of this survey to determine whether a specific organ that became available should have been matched with a specific transplant recipient on a transplant programs waiting list, or whether another person on the waiting list should have received the organ.
X053
(1)
Prior to placement on the centers waiting
list, a prospective transplant candidate must receive a
psychosocial evaluation, if possible.
Interpretive Guidelines
Review the written patient selection policy to verify that it contains a requirement for a prospective transplant candidate to receive a psychosocial evaluation by a qualified healthcare professional PRIOR TO PLACEMENT ON THE WAITING
LIST. The policy is expected to (1) indicate the length of time in which the psychosocial evaluation is deemed to be current, (2) identify the qualified healthcare professionals who may complete these evaluations (it is expected that these professionals would have knowledge of transplantation), and (3) include the follow-up and referral procedures if a transplant candidate requires such activities.
While the transplant program has flexibility in the specific
psychosocial tool to be used, the psychosocial evaluation is expected to be completed and to be focused on the
individuals suitabilityfor transplantation. It is expected that a psychosocial evaluation of this nature would be conducted by transplant program personnel and would address the following:
1) social, personal, housing, vocational, financial, and environmental supports; 2) coping abilities and strategies; 3) understanding of the risks and benefits of transplantation; 4) ability to adhere to a therapeutic regimen; and 5) mental health history, including substance or alcohol use or abuse and how it may impact the success or failure of organ transplantation.
The psychosocial evaluation is expected to be
age appropriate. Similar to psychosocial evaluations in other areas, in cases of
young pediatric patients, the evaluation would include interviews with the
parents/guardians.
Verify in the sample of post-June 28, 2007, transplant recipient medical records that the psychosocial evaluation
was completed by a person authorized under the programs policy before that potential recipient was placed on the UNET and transplant programs waiting lists. UNET is the secure Internet-based transplant database operated by the contractor for the OPTN (UNOS) for the nations transplant programs and Organ Procurement Organizations to register patients and donors on the waiting list and for transplantation. In each case, if a referral was made for further psychosocial evaluation before it could be determined whether an individual was to be placed on the UNET waiting list, verify that additional evaluation was completed as required by the transplant programs policies and procedures for follow-up and referral.
It is expected that in nearly all cases, a psychosocial evaluation is possible and should be conducted as part of the determination of whether or not someone would be a suitable transplant candidate. There arerare or emergency situations when a psychosocial evaluation cannot be completed prior to transplantation due to the patients medical condition and with the absence of family or others that can provide information/insight into the psychosocial history of the patient.
In such cases, verify that documentation is included in the transplant patients medical record that describes the reason a psychosocial evaluation was waived or unable to be completed, due to the need for emergency intervention or exceptional circumstances and that no family or others were
available to address the psychosocial history of the patient. Examples of these exceptional or emergent circumstances may include untreatable encephalopathy, massive liver trauma, and acute (fulminant) liver failure (e.g., Tylenol overdose, mushroom poisoning).