However, one new HCFA condition, on organ donation, has been completed, and is in the Federal Register, (FR doc. 98-16490) as of June 22. The organ donation changes will take effect August 21.

The rationale for this change has been widely publicized by Donna Shalala, Secretary for HHS. Her intent is to make more organs available, thus reducing the deaths of those awaiting transplants. It was felt that "potential donors" were being missed and with better identification there will be more donors.

These changes must be in place in order to continuing participating in the Medicare program. If your hospital is under the Prospective Payment System, it must set up a system to notify their regional organ procurement organization about patients who die or "whose death is imminent in the hospital."

Changes to hospitals will include coming up with methods to identify and refer more deaths to the organ procurement groups. Hospitals will also work with the organizations to ensure that the family of every potential donor knows about its option to donate organs and tissues. Some states already have organ procurement laws that are similar to these conditions of participation and are reported to have seen an increase of up to 40% in organ donations.

The JCAHO standards RI.2 require that a hospital has a policy and procedures, developed with the medical staffs’ participation for the procuring and donation of organs and other tissues.

1. The standard RI.2 has been considered an underscored standard by JCAHO and has been a focus in 1998.

2. Changes related to the new federal standards will make this another target of review. The federal standard will set the expectation of what should be in the policy. The survey will undoubtedly measure the standard at the level of the staff, so just having a policy is not enough.

3. Be sure there is a plan for implementation and evaluation that shows the policies revised, or developed is a good one.