Medicare Tweaks Kidney Transplant Payment Model Through 2031
Published Date: 6/1/2026
Rule
Summary
Starting July 1, 2026, Medicare is updating the Increasing Organ Transplant Access (IOTA) Model to help kidney transplant hospitals do even better at getting more people transplanted and improving care quality. These changes affect hospitals involved in kidney transplants and aim to make the process smoother and more effective, with new payment rules that reward success. This update is part of a 6-year plan running through 2031 to save more lives and boost patient experience.
Analyzed Economic Effects
11 provisions identified: 6 benefits, 3 costs, 2 mixed.
Performance-Based Payment Formula
An IOTA participant with a final performance score greater than 60 receives an upside payment calculated as: (final score − 60) ÷ 40 × $15,000 × (number of kidney transplants furnished to attributed Medicare patients during the performance year). Downside payments apply for final scores of 40 or lower beginning in Performance Year 2.
Medicare Advantage Included in Payments
CMS will include Medicare Advantage (MA) beneficiaries in the calculations for the IOTA Model's upside and downside risk payments. This change is finalized for Performance Year 2 and later, so counts of Medicare patients used to determine payments now include MA beneficiaries as well as Medicare FFS.
Downside Payment Due Within 60 Days
IOTA participants that owe a downside risk payment must remit the full payment to CMS in a single payment within 60 days after the date on which the demand letter is issued. If full payment is not received within 60 days, the remaining amount will be considered a delinquent debt.
Medicare Patient Notifications and Reviews
IOTA participants must inform their IOTA waitlist patients who are Medicare beneficiaries about individualized organ offer acceptance criteria at least once every 6 months while on the waitlist. They must notify Medicare beneficiaries when their waitlist status changes in a way that affects organ offers, include the reason and how to become active again, notify the dialysis facility and managing clinician where applicable, and send status-change notices within 10 days. Notices may be electronic if the patient has opted for electronic communications.
Updated Quality Metric Scoring Rules
CMS updated the composite graft survival rate metric by adding a modified risk-adjustment framework based on the Scientific Registry of Transplant Recipients, excluding multi-organ transplants from the metric, and changing how points are allocated for performance on this metric. These updates feed into participants' quality-domain scores used for payments.
Termination and Monitoring Enhancements
CMS may monitor the transparency provisions (such as review of acceptance criteria, semiannual reviews, and status-change notifications) and may terminate an IOTA participant if the Department of Health and Human Services (HHS) or the Organ Procurement and Transplantation Network (OPTN) determines the participant violated OPTN policies or certain HHS regulations. CMS updated its termination sources and monitoring authority in this rule.
Estimated Federal Savings of $60 Million
CMS estimates that the finalized changes to the IOTA Model will increase net Federal savings by $60,000,000. This estimate is presented in the rule's analysis of costs and benefits.
Higher Minimum Transplant Volume
To be eligible for the IOTA Model, a kidney transplant hospital must have performed at least 15 kidney transplants per year for adults during each baseline year. This raises the previous minimum from 11 to 15 transplants per year and takes effect for Performance Year 2 beginning July 1, 2026.
Exclude VA and Military Facilities
Department of Veterans Affairs (VA) medical facilities and military medical treatment facilities (MTFs) are excluded from eligibility to participate in the IOTA Model for Performance Years 2 through 6. CMS finalized this exclusion because Medicare generally does not pay for services furnished by those federal facilities.
Public Posting of Waitlist and Donor Criteria
IOTA participants must publicly post their patient waitlist selection criteria on a website and keep it up to date by the end of each performance year. Hospitals that perform living donor transplants must post living donor selection criteria by the end of Performance Year 2 and update it each subsequent year; the IOTA Model website will publish these items by the end of the second quarter of each subsequent performance year.
Health Equity Plan Requirement Removed
CMS is removing the voluntary Health Equity Plan (HEP) submission option for IOTA participants. CMS explained the voluntary HEPs require participant time and resources and are being removed so resources can be focused on the model's core objectives and mandatory requirements.
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