Beyond the Surface: How New Metrics Are Rewiring Organ Procurement

MCLEAN, Va. – October 27, 2026 — In the high-stakes ecosystem of American healthcare, few sectors operate under the intense pressure of the organ donation and transplantation network. It is the ultimate supply chain, where performance is measured not in quarterly profits, but in human lives saved. For years, this system has navigated severe regulatory headwinds, primarily driven by federal mandates demanding higher yields and stricter accountability. Yet, as any strategist will tell you, true resilience requires looking beneath surface-level volatility to understand the granular mechanics of success. Today, the Association of Organ Procurement Organizations (AOPO) took a definitive step toward engineering that resilience, announcing that two new performance measures—the Referral Rate and Approach Rate—have been formally endorsed by the Partnership for Quality Measurement (PQM).

Rethinking the Scorecard: Process vs. Outcome

Currently, the Centers for Medicare & Medicaid Services (CMS) evaluates the nation's 45 Organ Procurement Organizations (OPOs) using a rigid, outcome-only framework established in a landmark 2020 final rule. Under this system, OPOs live and die by two metrics: the Donation Rate and the Transplant Rate. While these outcome measures successfully doubled the number of high-performing OPOs and halved underperformers between 2021 and 2023, they act as blunt instruments. They tell regulators the final score, but they offer operators zero insight into how the game was won or lost.

Outcome metrics are essential for accountability, but they are insufficient for continuous value creation. An OPO can facilitate a perfect donation process, only to have the organ rejected by a transplant center—a variable entirely outside the procurement team's control. This dynamic creates a volatile operating environment where OPOs face the existential threat of decertification without a clear, data-driven roadmap for internal improvement.

Enter the newly PQM-endorsed Referral Rate and Approach Rate. Developed through AOPO's multi-year Performance Measurement Project in partnership with 53 OPOs and the analytics firm Econometrica, Inc., these are process measures. They are designed to capture the critical upstream moments that dictate the downstream outcomes.

"Outcome measures tell us what happened. Process measures can help us understand why it happened and where there may be opportunities to improve," noted Dr. Jean O'Connor, Health Practice Area Director at Econometrica. "A strong performance measurement system should provide both perspectives, giving organizations meaningful information they can use to strengthen processes and improve performance."

Accountability vs. Compliance: The Regulatory Headwinds

The endorsement of these measures by PQM—a consensus-based entity operated by Battelle for CMS—arrives at a pivotal moment. The industry is currently bracing for a new wave of federal scrutiny. In January 2026, CMS issued a proposed rule to further strengthen federal oversight and bolster the framework for re-certification cycles. Furthermore, March 2026 guidance from CMS doubled down on patient protections, emphasizing that grieving families must be given time to make informed decisions without coercion.

Within this charged atmosphere, the introduction of process metrics has sparked a nuanced debate. Some patient advocates and regulatory analysts view industry-led metrics with a degree of skepticism. As one healthcare policy analyst observed during the public comment phases of recent regulatory updates, there is an inherent friction when an industry operating under the threat of decertification begins designing its own scorecards. The fear is that process metrics could be weaponized to shield underperforming OPOs, creating a facade of compliance that distracts from stagnant actual organ yields.

However, looking at the mechanics of resilience, this skepticism may miss the broader strategic picture. Process metrics do not replace outcome metrics; they contextualize them. You cannot mandate a higher transplant rate without first optimizing the referral pipeline.

"The endorsement of these measures through a rigorous, independent process marks an important milestone for the OPO community and for the patients and families our system serves," said AOPO President Allison Erickson. "Strong performance measurement should help organizations understand where opportunities exist, improve processes and quality, and ultimately increase the number of lifesaving organs available for transplant. These measures move us toward a more comprehensive and actionable approach to evaluating donation performance."

Inside the Critical First Hours: Data-Driven Decisions

To understand the identifying marks of a winner in this space, one must look at the critical first hours of the donation pathway. The Referral Rate measures the timeliness and appropriateness of hospital referrals to the OPO. It is the absolute genesis of the value chain. If a hospital fails to notify the OPO of a potential donor in a timely manner, the opportunity is permanently lost, regardless of the OPO's downstream efficiency. By quantifying this step, OPOs can identify specific hospitals or wards that require targeted education and operational alignment.

Similarly, the Approach Rate evaluates whether eligible families are provided the opportunity to have a donation conversation. This is perhaps the most delicate interaction in modern medicine. Procurement coordinators must navigate profound grief, cultural nuances, and the strict ethical mandates of informed consent. Standardizing the measurement of these approaches—ensuring they happen consistently and equitably across all demographics—is a monumental data science challenge.

By grounding these measures in the Donabedian Model of healthcare quality, Econometrica and AOPO have translated highly subjective human interactions into objective, actionable data. This allows procurement networks to identify variations in their approach strategies, reduce regional disparities, and ensure that every eligible family is given the support needed to make an informed choice.

"This work has always been about developing measures OPOs can use to learn, improve performance, and better serve donor families and patients waiting for transplant," stated AOPO CEO Steve Miller. "PQM's endorsement demonstrates the value of bringing together data, operational expertise, and diverse perspectives to build performance measures that reflect how organ donation actually works."

The Pipeline to Permanence

The endorsement of the Referral and Approach rates is not the culmination of AOPO's strategy, but merely the foundation. To truly transition from reactive compliance to proactive permanence, the industry is preparing a broader suite of metrics. In July 2026, AOPO unveiled an eight-measure quality improvement framework. The next wave of these pipeline measures—focusing on donor management goals, organs recovered per donor, and overall organ utilization rates—is slated for submission to PQM in November 2026.

This comprehensive approach signals a maturation of the organ procurement industry. Rather than simply bracing for the next CMS audit or fighting federal mandates, leading OPOs are fundamentally rewiring how they define and measure success. They are acknowledging that while federal regulators set the floor for acceptable outcomes, it is the operators themselves who must build the operational ceiling.

In an unpredictable global healthcare landscape, the organizations that thrive are those that dissect their own processes before regulators do it for them. By embracing rigorous, independently validated process metrics, the organ donation community is building a more resilient supply chain. It is a strategic pivot that proves consistent value creation is never an accident of favorable outcomes, but the result of meticulously managed processes.