The federal executive branch Office of Management and Budget recently requested input on federal agency regulations that should be rescinded. Few if any qualify more obviously on, scientific, medical, practical and perhaps constitutional grounds than CMS’ governing rule on organ donation.

SID&T submitted:

“There is a documented poor historical record of regulatory overreach and abject failure of the Centers for Medicare and Medicaid Services (CMS) to manage and evaluate the Organ Procurement Organization system. [1]

Since adopting the flawed governing rule, twenty independent peer-reviewed studies have delineated the fatal flaws in CMS's regulation. [2]

Additionally, Congress mandated and funded a highly regarded study by the National Academies of Science, Engineering, and Medicine (NASEM). [3] True experts in the transplant and donation fields have rightly lauded its analysis, conclusions, and recommendations. To date, both CMS and Congress have ignored NASEM's findings. CMS has continued its long history of overreach and failure, while Congress has unfortunately been distracted from its duty by sensationalism.”

Citations

1. https://sidandt.org/news/latest-news/the-repetitive-history-of-cms-failing-patients-and-donors-with-flawed-performance-metrics-for-organ-procurement-organizations

2. https://sidandt.org/the-science/peer-reviewed-science

3. https://sidandt.org/the-science/nasem-study-confirms-key-advocacy-points