Comment on CMS-2026-1256-0002

Summary: Gift of Hope Organ & Tissue Donor Network, a non-profit organ procurement organization, opposes several provisions in the proposed rule that would impose significant financial and administrative burdens on IOPOs. They argue that the proposed cost reconciliation for non-renal organs lacks a proper risk assessment, lacks a necessary margin floor for sustainability, and creates operational hurdles regarding payer mix and overhead allocation.