Get Full Government Meeting Transcripts, Videos, & Alerts Forever!
Get email alerts on the Public Comment Analysis topic
No spam. Unsubscribe anytime.
HRSA and OPTN present public‑comment analysis for DCD and rabies policy proposals
Summary
At an open OPTN executive committee meeting, HRSA analyst Brianna reported a thematic review of public comments on donation‑after‑circulatory‑death (DCD) and rabies transmission proposals: 91 unique DCD comments (seven themes) and 27 rabies comments (eight themes), with reporting/transparency and NRP among the dominant concerns. Committees will adjudicate changes before HHS review and a board vote.
Brianna, an HRSA staff member, told the OPTN executive committee that the donation‑after‑circulatory‑death (DCD) proposal drew 91 unique public comments that were coded into seven themes; the most frequent theme was reporting and transparency. "This is a really important component part of the federal government's notice and comment rulemaking," she said, describing a move from sentiment scoring to a more substantive, thematic analysis aimed at policy‑relevant edits.
The HRSA review found a high share of individual (rather than organizational) commenters on the DCD proposal and said the OPO committee and the DCD work group will take a deeper dive into the themes. Brianna said the analysis "emphasized substantive concerns and proposed policy changes" and excluded exact duplicate submissions so as not to double‑count identical comments.
On a separate but related protocol, Brianna reported that 27 unique comments were coded for the rabies transmission and prevention proposal and that eight issue themes emerged. Commenters raised operational concerns, including how CDC consultation would be implemented, how screening definitions would be applied, and how transplant candidates who receive an organ with a possible rabies risk would be informed. She said some commenters worried that greater emphasis on rabies risk could prompt organ nonuse.
Dr. John McGee, who chaired the meeting, said he was impressed with the rigor and speed of the new approach. "I was quite impressed with the steps in it," he said, praising the move toward integrating public comment into committee decision‑making.
Next steps, as described by HRSA and committee leadership, are for the relevant committees and work groups to adjudicate each theme and determine whether draft policy language needs revision. Where the committees see no change is warranted, they will document the rationale. HRSA said it will participate throughout the process and that any final proposed language will undergo an HHS review before the OPTN board votes.
Brianna and committee leaders said the program expects the contractor now being onboarded to take over much of the analytic work, but that HRSA surge support will remain engaged during the transition. The OPO committee will review the full analytic decks on the OPTN360 secure site before any subsequent policy actions.
