Explainer. On Oct. 30, Medicare changed the scorecard for the organizations that decide whether a donated organ ever reaches a patient. Under the final rule, a pancreas sent only for islet cell research will no longer count as a transplant when no transplant happens.
That sounds technical. It isn't. The score decides who keeps the job.
Who these groups are
Organ procurement organizations, or OPOs, hold federal certification to recover organs in assigned territories. They get donor authorization, recover the organs and coordinate delivery to transplant programs. According to the CMS press release, more than 49,000 transplants were performed in the U.S. in 2025, while more than 100,000 Americans are waiting.
Since a 2020 rule, CMS grades each OPO on two numbers: a donation rate and a transplantation rate. The CMS fact sheet says top-tier groups get recertified for four years, middle-tier groups must compete to keep their territory, and groups with only bottom-tier territories are decertified.
What changed on Oct. 30
A donor whose pancreas goes only to islet cell research still counts toward the donation rate. That pancreas no longer counts toward the transplantation rate. CMS says the change makes sure scores "reflect organs transplanted into patients."
OPOs must also keep records showing what happened to every organ they send for research. CMS describes this tracking as a new requirement. The old metric let a research-only pancreas count toward the transplant rate.
The rule also defines "unsound medical practices," including failures in governance, donor evaluation, and procurement, allocation and transport. CMS says that gives it a clear basis to decertify an OPO immediately in urgent cases.
What the records do not show
CMS does not say in either document how many OPOs leaned on research pancreases to lift their transplant scores, or how many will drop a tier because of this change. It does not name any group. The agency frames the pancreas change as a measurement refinement that will "better incentivize" both research and transplants. Nothing here proves that any OPO gamed the old metric.
CMS also says that since the 2020 rule, donations rose 36% and transplants rose 30%. That is the agency's own claim. These pages don't include the underlying data.
Who pays and who benefits
Patients on the list depend on these groups to recover usable organs. If a group's score is propped up by organs that never reach a patient, it can keep a territory that a stronger group could serve. The rule lets high-performing OPOs compete for multiple territories and requires an outgoing group to cooperate with the one replacing it.
The fact sheet says CMS "will be moving to decertify tier 3 OPOs." The next useful step is to watch for that list. The open question: once research pancreases come out of the math, which groups fall into the bottom tier?