Comment on the U.S. Department of Health and Human Services (HHS) interim rules for organ procurement organizations

To: Healthcare Finance Administration, Dept. of Health and Human Services
From: Thomas A. Gonwa, MD, FAACP - President, ASTP
Date: October 26, 1994

Date posted on the Web: July 25, 1996

Dear Sirs:

The American Society of Transplant Physicians (A S.T.P.) would like to comment on the recently published interim rules for organ procurement organizations. The A S.T.P. is in favor of the published rules with one area of comment. The proposed regulations define the composition of the board of organ procurement organizations. As such, they state that the O.P.O. board is required to have as a member, a transplant surgeon from each participating hospital. The A.S.T.P. would differ with this position. The A S.T.P. represents the majority of practicing transplant physicians within the United States. Transplant physicians are the individuals who, in most cases, render the care to potential transplant recipients prior to organ transplantation. As such, the transplant physicians have a great interest in the allocation of organs and the smooth running of the organ procurement organizations. We believe that a transplant physician from each transplanting institution should also be designated as a constitutive member of the O.P.O. board. This would allow transplant physicians who render the majority of care to these patients prior to transplant and are intensely interested in obtaining transplantation for our patients, a voice on the O.P.O. board. Unfortunately this is not the case in most O.P.O.s around the country and should be rectified. The A.S.T.P. thanks the agency for the opportunity to comment on the proposed rules.

Sincerely yours,

THOMAS A. GONWA, M.D., F.A.C.P. President

TAG/eg

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