Comment on CMS-2026-1256-0002
Gift of Life Donor ProgramOpposeAdvocacy
Summary: The Gift of Life Donor Program (GLDP), a non-profit organ procurement organization, opposes the proposed rule because it would eliminate the financial margins necessary for OPOs to operate safely and sustainably. They argue that the proposed reconciliation of non-renal organ costs fails to account for the "Medicare share" of expenses, risks forcing OPOs to operate at a loss, and could stifle innovation, capital investment, and workforce stability.
Please accept the attached comment on behalf of Gift of Life Donor Program.