Comment on CMS-2026-1256-0002
OneLegacyOpposeAdvocacy
Summary: OneLegacy, a federally designated Organ Procurement Organization, opposes the proposed rule because it threatens the financial viability of IOPOs and HCLs by expanding retrospective cost reconciliation to non-renal organs. They argue that the proposal exceeds CMS's statutory authority, creates subjective and arbitrary standards through the "prudent buyer" principle, and unfairly restricts allowable costs for public outreach and employee morale.
OneLegacy (CAOP) is a federally designated Organ Procurement Organization headquartered in Azusa, CA. OneLegacy appreciates the opportunity to provide the attached comments to CMS’s Proposed Rule (1849-P) for proposed changes to payment policies issued in the Federal Register (91 FR 19312) dated April 14, 2026. Our comments relate to the proposed changes for organ acquisition and reasonable cost payment policies, and reimbursement appeals for Independent Organ Procurement Organizations (IOPOs) and Histocompatibility Laboratories (HCLs). In summary, we share our concerns with these changes that, if finalized, would severely threaten the financial viability of IOPOs and HCLs.