On behalf of the Cystic Fibrosis (CF) Foundation, we appreciate the opportunity to provide feedback on the Organ Procurement and Transplantation Network Membership and Professional Standards Committee (MPSC)’s proposal to update criteria for post-transplant graft survival metrics.
The CF Foundation has previously recommended OPTN consideration of several measures to mitigate disincentives for transplant programs to accept extended donor criteria organs and medically complex recipients. We therefore support the MPSC’s proposal to change the threshold for MPSC review of adult 90-day and 1-year conditional on 90-day graft survival from 50% probability that the transplant program’s hazard ratio is greater than 1.75 to 50% probability that the transplant program’s hazard ratio is greater than 2.25. We agree that increasing the flagging threshold for these metrics may reduce transplant program concern and uncertainty regarding MPSC performance review, encourage transplant programs to consider more marginal donor organs and more medically complex recipients, and support increased organ utilization and transplants.
With our previous recommendations in mind, we would also like to note that, though the MPSC’s proposal specifically refers to the anticipated impact on transplant program acceptance of extended donor criteria organs, we are optimistic that the proposed changes would also encourage transplant programs to consider transplanting more medically complex organ recipients. This is especially important of the context of CF, given the inherent multiorgan complications of CF including malnutrition, diabetes, and liver disease as well as chronic (and frequently multidrug-resistant) infections, potential for prior transplantation, and other complicating factors that may be present in cases of CF patients requiring lung transplantation.
Finally, the CF Foundation emphasizes that the proposed changes in the flagging threshold for adult 90-day and 1-year conditional on 90-day graft survival do not diminish the need for, or value of, existing OPTN programs designed to improve performance through education, coaching, and peer mentoring, such as the Individual Member-Focused Improvement program. Though voluntary, we believe that such programs are immensely useful for OPTN member transplant programs and may even mitigate some concern about raising the flagging threshold.