Comment on CMS-2026-1256-0002

Summary: Midwest Transplant Network, Inc. (MTN), an organ procurement organization, opposes the proposed rule because it would fundamentally reshape non-renal organ acquisition reimbursement and impose a "zero-margin" model. They argue that the proposal lacks sufficient statutory authority, ignores the operational realities of 24/7 organ procurement readiness, and could undermine the donation system by restricting investments in innovation, public education, and donor family aftercare.