The Alliance

Insight Series

The Alliance insight series offers critical resources for stakeholders across the donation and transplantation continuum. For each topic, you can find related action items, tools, and references.

September 2025
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A Note About Content

Some legacy resources on this website may refer to UNOS in place of the OPTN, reflecting common usage at the time of publication when the two were often used interchangeably. In recent years, significant work has gone into distinguishing these as separate entities: the OPTN is the nationwide organ transplant network established by federal law, while UNOS is one of several organizations currently under contract to support OPTN operations. We’ve preserved these resources as originally published, but recommend referring to current terminology for the most accurate understanding of each organization’s role.

SEPTEMBER 2025

ABO verification during transplantation is a critical safeguard to ensure patient safety and uphold regulatory compliance for both transplant recipients and living donors. This safeguard is essential to prevent adverse outcomes and support the integrity of transplant procedures. In December 2024, the Centers for Medicare & Medicaid Services (CMS) updated their interpretive guidelines for 42 CFR §482.92, aligning them more closely with the Organ Procurement and Transplantation Network (OPTN) policies 5.8.B Pre-Transplant Verification Upon Organ Receipt and OPTN policy 14.7 Living Donor Pre-Recovery Verification. This alignment reinforces the importance of thorough verification protocols at key points in the transplant and living donation processes.

ABO Verification during transplantation is a critical element to ensure patient safety and maintain regulatory compliance for transplant recipients and living donors.

How can transplant centers improve ABO Verification Compliance

IMPROVING COMPLIANCE	ACTION
Workflow, Processes and Documentation	Utilize EMR to create intra-op forms to document Ensure all required verification components are a hard stop, so all required elements are met Includes prompts for the licensed health care professional(s) and transplant surgeon(s) to acknowledge When utilizing EMR Pre-Transplant Verification forms it is important to remember that these forms are customizable, and transplant programs can make changes to meet the needs of their program Development of a downtime process
Sustain Compliance through Monitoring	Create EMR report(s) to monitor Pre-Transplant Verification before Organ Receipt, Pre-Transplant Verification Upon Organ Receipt, and Pre-Transplant Verification for Extra Vessels Daily monitoring of compliance by the quality team is essential
Education	Annual in-service with OR circulators Create Tip-sheets for surgeons
Engagement & Communication	Collaboration between the Transplant Center and the OR is critical for compliance Identified a transplant champion in the OR, especially if no dedicated staff Many transplant centers find it helpful to have someone on-call who is available for troubleshooting issues that may arise and must be resolved in real-time
Be Aware of Required Reporting	Create a process where the OPTN Patient Safety Contact(s) are notified in real-time of any reportable events as outlined in OPTN Policy 18.5.A and 18.5.B.

The following are excerpts from OPTN policy (August 2025)

In December 2024, CMS further aligned their interpretive guidelines of 42 CFR §482.92 with OPTN policy 5.8.B Pre-Transplant Verification Upon Organ Receipt and OPTN policy 14.7 Living Donor Pre-Recovery Verification. Pre-Transplant Verification Prior to Organ Receipt was removed as a CMS requirement in July 2012 but remains an OPTN requirement in OPTN policy 5.8.A.

TRANSPLANT ABO VERIFICATION

OPTN Policy 5.8.A — Pre-Transplant Verification Prior to Organ Receipt

Requirements (when surgery begins prior to organ receipt):

The intended recipient must be present in the operating room.
The verification must occur either:
- Prior to induction of general anesthesia
- Prior to incision if the patient has been receiving continuous sedation prior to arrival in the OR
Use at least one acceptable source (see table) to verify all required information. The OPTN organ tracking system may be used to assist.

Table 5-2: Pre-Transplant Verification Prior to Organ Receipt Requirements
The transplant hospital must verify all of the following information:	Using at least one of the following:	By the following individuals:
Expected donor ID	OPTN computer system Recipient medical record	Two licensed health care professionals
Expected organ (and lung laterality if applicable)	OPTN computer system Recipient medical record	Two licensed health care professionals
Expected donor blood type and subtype (if used for allocation)	Donor blood type and subtype source documents OPTN computer system	Two licensed health care professionals
Recipient unique identifier	Recipient identification band	Two licensed health care professionals
Recipient blood type	OPTN computer system Recipient blood type and subtype source documents Recipient medical record	Two licensed health care professionals
Expected donor and recipient are blood type compatible (or intended incompatible)	OPTN computer system Recipient medical record Attestation following verification of donor and recipient blood types	Two licensed health care professionals
Last updated: January 2025 \| Source: OPTN Policy Website

OPTN Policy 5.8.B — Pre-Transplant Verification Upon Organ Receipt

Requirements (at time of organ receipt in the OR):

The intended recipient must be present in the operating room.
Verification occurs after the organ arrives in the OR, but prior to anastomosis of the first organ.
Use at least one acceptable source (see table) to verify all required information. The OPTN organ tracking system may be used to assist.

Table 5-3: Pre-Transplant Verification Upon Organ Receipt Requirements
The transplant hospital must verify all of the following information:	Using at least one of the following:	By both of the following individuals:
Donor ID	External and internal organ package labels Documentation with organ	Transplant surgeon Licensed health care professional
Organ (and laterality if applicable)	Organ received	Transplant surgeon Licensed health care professional
Donor blood type and subtype (if used for allocation)	Donor blood type and subtype source documents	Transplant surgeon Licensed health care professional
Recipient unique identifier	Recipient identification band	Transplant surgeon Licensed health care professional
Recipient blood type	Recipient blood type source documents Recipient medical record	Transplant surgeon Licensed health care professional
Donor and recipient are blood type compatible (or intended incompatible)	OPTN computer system Recipient medical record Attestation following verification of donor and recipient blood types	Transplant surgeon Licensed health care professional
Correct donor organ has been identified for the correct recipient	Recipient medical record OPTN computer system Attestation following verification of donor ID, organ, and recipient unique identifier	Transplant surgeon Licensed health care professional
Last updated: January 2025 \| Source: OPTN Policy Website

LIVING DONOR VERIFICATION

OPTN Policy 14.7 — Living Donor Pre-Recovery Verification

Requirements:

The verification must occur prior to the induction of general anesthesia on the day of the living donor recovery.
Recovery hospitals must use at least one of the acceptable sources (see table) to verify all of the required information. The OPTN organ tracking system may be used for assistance.

Table 14-13: Pre-Recovery Verification Requirements
The recovery hospital must verify all of the following information:	Using at least one of the following:	By both of the following individuals:
Donor ID	Donor identification band containing the donor ID Donor identification band and OPTN computer system	Recovery surgeon Licensed health care professional
Organ type and laterality (if applicable)	OPTN computer system	Recovery surgeon Licensed health care professional
Donor blood type and subtype (if used for ensuring transplant compatibility or allocation)	Donor blood type and subtype source documents	Recovery surgeon Licensed health care professional
Intended recipient unique identifier	Recipient medical record OPTN computer system	Recovery surgeon Licensed health care professional
Intended recipient blood type	Recipient medical record OPTN computer system	Recovery surgeon Licensed health care professional
Donor and intended recipient are blood type compatible (or intended incompatible)	OPTN computer system Recipient medical record Attestation following verification of donor and recipient blood types	Recovery surgeon Licensed health care professional
Correct donor organ has been identified for the correct intended recipient	Donor medical record OPTN computer system Attestation following verification of donor ID, organ, and recipient unique identifier	Recovery surgeon Licensed health care professional
Last updated: January 2025 \| Source: OPTN Policy Website

OPTN REQUIRED REPORTING EVENTS

Table 18-3: Required Reporting by Transplant Hospitals

Transplant hospitals must report if:	To the:	Within 72 hours after:
A transplant of the incorrect organ into an organ recipient occurs	OPTN Patient Safety Reporting Portal	The transplant hospital becomes aware
A transplant of an organ into the incorrect organ recipient occurs	OPTN Patient Safety Reporting Portal	The transplant hospital becomes aware
A donor organ is identified as incorrect during pre-transplant processes conducted according to either OPTN Policy 5.8.A: Pre-Transplant Verification Prior to Organ Receipt or OPTN Policy 5.8.B: Pre-Transplant Verification Upon Organ Receipt	OPTN Patient Safety Reporting Portal	The transplant hospital becomes aware
The potential transplant recipient is identified as incorrect during pre-transplant processes conducted according to either OPTN Policy 5.8.A: Pre-Transplant Verification Prior to Organ Receipt or OPTN Policy 5.8.B: Pre-Transplant Verification Upon Organ Receipt	OPTN Patient Safety Reporting Portal	The transplant hospital becomes aware
An organ was delivered to the incorrect transplant hospital and resulted in non-use of the organ	OPTN Patient Safety Reporting Portal	The transplant hospital becomes aware
The incorrect organ was delivered to the transplant hospital and resulted in non-use of the organ	OPTN Patient Safety Reporting Portal	The transplant hospital becomes aware
An ABO typing error or discrepancy is caught before or during pre-transplant processes conducted according to either OPTN Policy 5.8.A: Pre-Transplant Verification Prior to Organ Receipt or OPTN Policy 5.8.B: Pre-Transplant Verification Upon Organ Receipt	OPTN Patient Safety Reporting Portal	The transplant hospital becomes aware
Last updated: January 2025 \| Source: OPTN Policy Website

Table 18-4: Living Donor Event Reporting

Recovery hospitals must report if:	To the:	Within 72 hours after:
A living donor organ recovery procedure is aborted after the donor has begun to receive general anesthesia.	OPTN Patient Safety Reporting Portal and the OPTN	The aborted organ recovery procedure
A living donor dies within 2 years after organ donation	OPTN Patient Safety Reporting Portal	The hospital becomes aware
A living donor is listed on the wait list within 2 years after organ donation	OPTN Patient Safety Reporting Portal	The hospital becomes aware
A living kidney donor begins regularly administered dialysis as an ESRD patient within 2 years after organ donation	OPTN Patient Safety Reporting Portal	The hospital becomes aware
A living donor organ is recovered but not transplanted into any recipient	OPTN Patient Safety Reporting Portal and the OPTN	Organ recovery
A living donor organ is recovered and transplanted into someone other than the intended recipient	OPTN Patient Safety Reporting Portal	Organ recovery
Last updated: January 2025 \| Source: OPTN Policy Website

Successful Utilization of Epic

How the workflows appear in Cerner.
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Customizable ABO Verification to ensure compliance
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a. Development of customizable ABO Verification to ensure compliance:

ABO PRE ORGAN ARRIVAL VERIFICATION RECIPIENT 1

ABO VERIFICATION RECIPIENT 2

ABO VERIFICATION LIVING DONOR 3

b. Correct order of operations in Epic is essential to complete ABO Verification successfully

c. Common Challenges with ABO Verification while using EPIC:

OR documentation relies on accurate creation of the organ record created ensure that a double verification process occurs during organ record creation
Delay in Surgeon signature after cases put required timelines in policy and implement system for following up and escalating
Epic foundation links charges to ABO Verification log posting. Delays in ABO Verification can lead to delays in posting charges
Erroneous ABOs cannot be deleted ensure a process around how to handle these, especially in light of point III
Timestamps or errors in documentation have to be resolved

d. ABO Verification Quality Report- utilize Epic tools to make it easy.

Preparing for a Regulatory Survey: ABO Verification

Transplant programs should ensure full compliance with the following OPTN Policies:

5.8.A — Pre-Transplant Verification Prior to Organ Receipt
5.8.B — Pre-Transplant Verification Upon Organ Receipt
14.7 — Living Donor Pre-Recovery Verification
18.5 — Patient Safety Event Reporting

Surveyors (CMS or OPTN) will expect well-defined, role-specific protocols, thorough documentation, and evidence of routine compliance monitoring. Clear workflows should outline timing of verifications (e.g., pre-induction or pre-incision), accepted verification sources, and which roles (licensed healthcare professionals and transplant surgeons) are responsible at each step.

Special Attention

Living donor procedures: Demonstrate verification of both donor and intended recipient identity and blood type compatibility before recovery, with documentation by the recovery surgeon and a licensed healthcare professional.
Multiorgan transplants: Verify each organ separately and show coordinated processes to prevent timing/documentation errors across teams and disciplines.

Tips & Tricks

Tip	What to Include / How to Execute
Create a Survey-Ready Binder (Digital or Physical)	Current policies & procedures and downtime protocols EMR screenshots showing verification steps and workflow timing Completed ABO verification logs or EMR evidence of completion Quality audit summaries and monitoring reports Label sections clearly so any team member can quickly find items a surveyor requests.
Run a Mock Verification Drill	Use a recent, de-identified case; include living donor or multiorgan if applicable. Walk through EMR documentation, timing checkpoints (pre-induction / pre-incision), and verification sources. Capture gaps and assign owners with due dates before survey day.
Know Your Champions	Identify ABO verification “go-to” staff (often OR circulators). Ensure they can explain processes end-to-end, locate documentation, and describe escalation/reporting pathways.
Use the Downtime Protocol as a Strength	Be ready to show where paper forms are stored and how staff are trained. Keep a few completed downtime forms handy as examples of compliant documentation.
Highlight Education & Monitoring	Maintain annual training logs and distribute tip sheets by role. If you monitor via EMR reports or dashboards, have a sample printed or ready on screen. Show trend data and actions taken—reinforcing continuous improvement and safety. Daily monitoring of compliance by the quality team essential
Last updated: January 2025 \| Source: OPTN Policy Website

A SPECIAL THANKS TO THE TRANSPLANT QUALITY CORNER WORKGROUP

Ashley Cardenas

MAS, MBA, FASTTransplant AdministratorRenown Transplant Institute

Allison Peck

MSN, CCTC RN-BCClinical Transplant Program Coordinator Kidney & Pancreas TransplantCedars Siani Medical Center

Abbey Olsen

MSN, RN, CCRNTransplant Quality ManagerUniversity of Utah Hospital

Adriana Kochi

MHA, CPHQTransplant Quality DirectorInova Fairfax Hospital

Melissa Robinson

Quality & Safety Director, Transplant Institute Loma Linda University Medical Center

Jenna Lawson

MSProgram Director, Pediatric TransplantVanderbilt University Medical Center

Lecia Snell Kinen

MSN, RN, CCTCManager, Quality and ComplianceKeck Medical Center at USC

Lindsay Smith

RN, MSNTransplant Quality DirectorVanderbilt University Medical Center

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