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OPTN board hears update on defining an "offer" and a kidney expedited-placement pathway; HRSA feedback pending

Organ Procurement and Transplantation Network Board of Directors · July 22, 2026
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Summary

At its April 16 meeting the Organ Procurement and Transplantation Network (OPTN) Board received an update from Secretary Justin Wilkerson on an allocation out-of-sequence work group that drafted an analytic definition of an "offer," criteria for an expedited pathway for kidneys and an audit framework; several projects remain paused pending HRSA review.

The Organ Procurement and Transplantation Network (OPTN) Board of Directors received an update April 16 on a multi-team effort to reduce allocation out of sequence and to make organ-offer activity auditable.

Justin Wilkerson, the board secretary and chair of the work group, said the group tackled three charges: create an analytic definition of an "offer," define conditions for an expedited pathway for kidneys, and develop monitoring tools for allocation out of sequence. "Allocation out of sequence work is intrinsically, aligned with OPTN modernization," Wilkerson said as he framed the work alongside planned system upgrades.

The teams included 38 community members—medical professionals, patients, transplant centers and organ procurement organization (OPO) staff—and received contributions from HRSA, Wilkerson said, singling out "Dr. Sarah Lasky and her data science team." The board was told that HRSA provided formal feedback on Feb. 9 and that some teams were temporarily paused while that feedback is integrated.

Wilkerson reported a sharp reduction in allocation out of sequence in spring 2025 and said the group identified a major barrier: the absence of a single, auditable definition of an "offer." He warned that prior practice recorded offers inconsistently (for example, only counting offers that resulted in transplantation), which prevented reliable statistics and auditing. The offer team drafted a concise definition that would require electronic recording of minimum components so offers can be tracked across programs.

Kevin Lee's expedited-pathway (EPP) team drafted initial organ-specific eligibility criteria to allow some kidneys to enter a faster placement pathway when clinically appropriate; Wilkerson described the kidney EPP as a pilot that could later inform expedited placement for other organs. He said the compliance team drafted an audit framework and reviewed a European-style concurrent-offer clock system as one option to speed decision timelines.

Board members asked whether the new offer definition would be applied retroactively. "I can't imagine that they're gonna go back and apply this," Wilkerson said, adding that some historical review would likely be needed for implementation but that broad retroactive application in a negative sense was not anticipated. He said final decisions about whether definitions become formal OPTN policy would follow board review of the drafts.

Several members pressed for clarity on implementation steps and technical requirements. Taylor Moundsen noted that OPTN policy already contains defined terms and recommended codifying the work group's definitions into policy so future proposals reference consistent language. Dr. Sarah Lasky reiterated that the draft includes both definitions and clarifying language to ensure offers are auditable in the data.

Wilkerson said the offer-team draft should be completed in a few meetings and turned over to the board, and he estimated the remaining drafting work could take "at most a couple more months" before final drafts are submitted. He cautioned that several proposals will require technology upgrades and policy work before they can be operationalized.

Next steps described to the board included integrating HRSA feedback, finishing drafts, running a public-comment period and presenting materials at scheduled town halls. The board did not take formal action on the AOS proposals at the April 16 session and the work will return to committee and board review for consideration of policy next steps.