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Board presses work group on auditing, hospital criteria and enforceability for DCD pauses
Summary
Board members asked how auditors will verify required time‑point documentation and whether hospitals uniformly have written criteria for withdrawal; members said implementation guidance should codify expectations so OPOs can be held accountable where policies are absent.
Several board members pressed the work group on how the new requirements will be audited and how OPOs will be held accountable when donor hospitals lack written criteria for withdrawal of life-sustaining therapy. "How will those time periods be audited, at the different sites?" asked Dan, seeking concrete auditing mechanisms for the two required education and neurologic-assessment time points.
PJ Garrity responded that auditors will look for an OPO policy regarding education and neuro assessments and then check donor charts to ensure the policy was followed. Sam raised the concern that many hospitals rely on physician and family judgment rather than uniform written criteria; PJ said where policies do not exist, the OPO must check in with the attending physician and family, and recommended codifying expectations in implementation materials to support accountability.
