February 2026
IN THIS ISSUE
- Summary
- Potential Barriers to Success
- Action
- Education
- Identification of Contracted Services
- Common Metrics
- Resources
- Contributors
- Feedback
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.
February 2026
IN THIS ISSUE
The Alliance Insight Series
Feedback & Suggestions Welcome
Your input is valuable to us as it helps improve our programs and offerings in order to provide you with vital updates and essential information. Please feel free to share your thoughts and ideas with us.
FEBRUARY 2026
CMS Conditions of Participation require transplant centers to monitor and evaluate the performance of all contracted services that may impact patient outcomes, regulatory compliance, and transplant program operations. Programs are increasingly expected, especially during CMS surveys, to demonstrate ongoing monitoring and reporting. These expectations highlight the need to standardize definitions, contractual expectations, documentation, and quality-monitoring frameworks.
| Topic | Actions / Considerations |
|---|---|
| Identification of Contracted Services |
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| Recommended Contract Practices |
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| Living Donor Contract Considerations |
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| Experience With Surveyors | Centers report that CMS surveyors increasingly request:
Simple yes/no compliance tracking is often acceptable as long as documentation is structured and consistent. |
| Questions for Centers to Consider |
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CMS guidelines (X-099, §482.96) require QAPI programs to monitor and evaluate the performance of services provided under contract or arrangement. The updated December 2024 guidance includes expanded expectations for living donor–related contracted services and emphasizes documentation, communication, and durable quality oversight.
| Category | Examples |
|---|---|
| Organ & Recovery-Related Services |
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| Laboratory & Diagnostic Services |
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| Aviation & Transportation |
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| Care Coordination / Waitlist Management |
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| Data, Technology & Infrastructure |
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| Living Donor–Specific Services |
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| Category | Common Metrics |
|---|---|
| Organ Procurement & Recovery |
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| HLA Laboratory |
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| Aviation |
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| Machine Perfusion / Device Support |
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| Logistics / Coordination |
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| Platforms / Technology |
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| Recovery Services |
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| Living Donor–Specific Metrics |
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Response Time
Communication and Coordination
Protocol Adherence
Documentation Accuracy
Patient Notification and Consent
Staff Training and Competency
Technology and Infrastructure
Clinician Satisfaction and Feedback
If there is content you feel that should be added or was lacking, we would like to hear from you. Positive feedback on what is working for you, is also welcomed. Thank you for taking the time to provide us with your feedback.